California Transparency in Supply Chains Act Statement

RoC Skincare

California Civil Code § 1714.43

Statement Regarding Slavery and Human Trafficking

At RoC Opco LLC (“RoC”), we are committed to conducting business in a legal, ethical, and responsible manner and to eradicating slavery and human trafficking from our supply chain.

This statement is made pursuant to the California Transparency in Supply Chains Act of 2010 (California Civil Code section 1714.43). It describes the extent to which RoC engages in verification, supplier audits, supplier certification, internal accountability, and training with respect to slavery and human trafficking in the direct supply chain for the tangible goods we offer for sale. RoC prohibits forced labor, human trafficking and child labor. Our program is maturing, and the disclosures below describe our efforts to date, including where those efforts are still being developed.

1.     VERIFICATION

Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery, and specifies if the verification was not conducted by a third party.

RoC operates a risk-based third-party due diligence program. Suppliers, vendors and other third parties complete a questionnaire and are screened against sanctions, anti-corruption, human-rights, modern-slavery and forced-labor criteria using automated tools together with trained human review before they are onboarded. In the most recent period, RoC screened 427 existing active vendors on an enterprise-wide basis and a further 36 new vendors through its onboarding portal, 15 of which were cleared subject to specific contractual provisions or enhanced due diligence.

This verification is conducted internally by RoC’s legal and compliance function using third-party screening data sources; it is not, at present, a supply-chain verification conducted by an independent third party engaged for that purpose.

2.    SUPPLIER AUDITS

Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, and specifies if the verification was not an independent, unannounced audit.

RoC establishes contractual audit and monitoring rights across its manufacturing and supply partners through its Supplier Code of Conduct and quality agreements. RoC does not, at this time, conduct a formalized program of independent, unannounced supplier audits directed specifically at slavery and human trafficking. A formalized supplier audit program that includes labor and human-rights criteria is a priority under development.

3.    CERTIFICATION

Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

RoC’s Supplier Code of Conduct, launched in March 2026, prohibits forced labor, child labor and human trafficking and requires suppliers to comply with applicable laws, referencing international frameworks including the UN Guiding Principles on Human Rights and ILO Forced Labor Conventions. As a condition of onboarding, direct suppliers are required to review and commit to the Supplier Code. As of the most recent period, all 24 of RoC’s manufacturing and supply partners have accepted and committed to the Supplier Code. This commitment constitutes a general acknowledgment of the Code as a whole, rather than an express, standalone certification of compliance with slavery and human trafficking laws specific to the supplier’s country of operation.

RoC’s standard supplier terms require goods and services supplied to RoC not to be produced using forced, prison, bonded or child labor.

4.    INTERNAL ACCOUNTABILITY

Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

RoC’s Code of Business Conduct sets the standards expected of all colleagues, and RoC expects its suppliers and business partners to uphold equivalent standards. Failure to follow the Code or applicable policies is subject to disciplinary action, up to and including termination of employment or of the business relationship.

RoC maintains a confidential, multilingual speak-up channel, available to colleagues and to external parties including suppliers and their workers, for reporting concerns — including concerns relating to forced labor or human trafficking — without fear of retaliation. In the most recent period, no concerns relating to labor or human-rights matters were raised through RoC’s supplier-facing channels.

5.    TRAINING

Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

RoC provides compliance training to relevant colleagues through its online learning platform, including annual certification of the Code of Business Conduct, which addresses human rights and the prohibition of forced and child labor. In the most recent cycle, 100% of colleagues completed this certification. RoC is developing role-based training for colleagues and management with direct responsibility for supply-chain management, focused specifically on identifying and mitigating human-trafficking and slavery risks.

6.    ADDITIONAL INFORMATION

RoC does not use prison labor in its operations. RoC will continue to develop its responsible-sourcing program and expects to strengthen these efforts over time.

Questions regarding this disclosure may be directed to Richard P. Davies, General Counsel & Chief Administrative Officer, at rdavies@rocskincare.com.

Signed by
Richard P. Davies

General Counsel & Chief Administrative Officer, RoC Opco LLC

Last updated: 16 August 2026