California Transparency in Supply Chains Act Statement

At e.l.f. Beauty, we are committed to conducting business in a legal, ethical, and responsible manner and recognize the importance of safe working conditions around the world. We are opposed to human trafficking, forced labor, child labor, harassment and abuse, and other violations of human rights at any level, and we are committed to ensuring that the manufacturers and suppliers we work with meet our standards.

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Below are our required disclosures under the California Transparency in Supply Chains Act of 2010.

Verification and Certification

Prior to engaging any new manufacturers, fillers, packagers, and suppliers (generally “Suppliers”), we internally evaluate each Supplier and require them to operate in compliance with our policies including but not limited to our Supplier Code of Conduct. In addition to internal assessments, we utilize third-party verification to ensure compliance with certain regulations and standards referred to in our policies and Supplier Code of Conduct after Supplier onboarding. Our Supplier Code of Conduct, in conjunction with our manufacturing and quality agreements, requires that our Suppliers be in full compliance with all applicable governmental, legal, regulatory and professional rules and regulations.

In addition to agreeing to a manufacturing and quality agreement, we require our Suppliers to agree in writing to, and adhere to, our Supplier Code of Conduct. Our Supplier Code of Conduct addresses working conditions for Suppliers (including paying fair wages and maintaining a safe and healthy workplace environment) and specifically prohibits, among other things, the use of involuntary or forced labor, human trafficking, child labor, human rights violations, animal testing, and harassment and abuse. In addition, our Supplier Code of Conduct requires that our Suppliers make a commitment to basic principles of human rights.

Our Supplier Code of Conduct does not at this time require our Suppliers to specifically certify that sub-suppliers comply with the laws regarding human trafficking and slavery of the country or countries in which the Suppliers are doing business, nonetheless, our Supplier Code of Conduct requires that suppliers extend their obligations as set forth in the Supplier Code of Conduct to their subcontractors.

Supplier Audits

Our internal audit team conducts periodic, announced onsite audits of our Suppliers, with the selection of Suppliers to be audited based on criteria such as geography, type of material, and impact to the business.

If our audit shows that a Supplier is in violation of our Supplier Code of Conduct or if we suspect a Supplier is in violation of any requirement of our Supplier Code of Conduct or our manufacturing or quality agreements, we will conduct an inquiry. If a potential violation is identified, we will address the issue with the Supplier and set expectations for how the situation is to be addressed. If a non-compliance issue is not resolved in a satisfactory manner, then we will re-evaluate our business relationship with that Supplier, up to and including termination of the business relationship.

Internal Accountability

We maintain internal accountability standards and procedures for contractors and Suppliers failing to meet company standards, including company standards regarding human trafficking and slavery. Non-compliance with our policies, including company standards regarding slavery and trafficking, can result in corrective action or termination, depending on the number of non-compliances found and their severity.

Training

We periodically provide specific company employees and management with specific formal training on human trafficking and slavery, including identifying and mitigating potential forced labor risks.