California Transparency in Supply Chains Act (SB 657)

Academy Sports + Outdoors (“Academy”, “we,” “us” and “our”) is committed to developing and maintaining a supply chain that is free from slavery, human trafficking, and child labor. As required under the California Transparency Supply Chains Act, we are disclosing our efforts to mitigate the risk of slavery, human trafficking, and child labor in our supply chain.

Compliance Requirements: We are committed to operating our global sourcing operations ethically, complying with all applicable laws and regulations. To this end, our Global Sourcing Requirements and Code of Vendor Conduct and our Terms and Conditions of Purchase (collectively, our “Vendor Compliance Requirements”) each incorporate standards that, among addressing other concerns, ensure our supply chain is free from slavery, human trafficking, and child labor. Our Vendor Compliance Requirements apply to all of our merchandise supply chain vendors (our “Vendors”), which include our licensed brand and private label merchandise vendors, manufacturing contractors, and to all goods sourced by us. Our Vendor Compliance Requirements require our Vendors to comply with applicable laws and regulations and prohibit our Vendors from engaging in slavery, human trafficking, and child labor. Our Vendors and their factories must comply with all applicable minimum working age laws and must not employ or use persons younger than the age of 14, for any reason, regardless of the laws, regulations, customs or guidelines of the country of origin. Any of our Vendors or factories found to be in violation of these requirements are subject to corrective action up to and including the termination of our existing purchase orders and our future business relationship with them.

Verification: Our "New Vendor On-Boarding Process” allows us to verify by several methods that our Vendors and their factories will be able to comply with our Vendor Compliance Requirements. Each factory we import goods from must be approved by our factory compliance team before we issue purchase orders to the Vendor or the factory. Vendors or factories that are unable to comply with our Vendor Compliance Requirements are not approved. Our factory compliance team conducts a screening of every new factory that we import goods from by requiring the factory to provide us with a recent social and security audit conducted by an approved independent audit firm. Annually, our factory compliance team engages a third-party firm to complete a country threat assessment for all countries where we import goods, with a concentration on countries known for involvement in human trafficking, slavery, terrorism, contraband, and other social responsibility factors. This country threat assessment is used by us to create a supply chain risk analysis of each factory that we import goods from. The performance of factory audits are prioritized based on the results of our supply chain risk analysis of each factory, as well as on other factors. Factory audit results are reviewed by our factory compliance team, who then either assist factories in remediating concerning issues or recommend to our internal business teams that we not initiate or otherwise discontinue conducting business with the factory.

Audits: All of our private label and licensed brand Vendors and their factories that we import goods from are subject to audits conducted by independent third-party auditors to monitor their compliance with our Vendor Compliance Requirements. Currently, we engage third-party audit firms to conduct announced audits of such factories. However, under our Terms and Conditions of Purchase, we may conduct unannounced audits at our discretion. Social and security audits of these factories are conducted by our third-party auditors. Our personnel may also conduct on-site inspections of factories and production of goods that we import. We are promptly alerted by our auditors to potential non-compliance requirements related to slavery, human trafficking, and child labor. During an audit, the auditors interview employees, verify employment records and conduct visual inspections of factory and dormitory settings. Our Vendors must maintain current and sufficiently detailed records to substantiate their compliance with our Vendor Compliance Requirements. The frequency of our audits is based on our risk assessment and prior audit findings. Audit findings are reviewed by our factory compliance team and corrective action plans are developed, if needed. If a corrective action plan is not followed, we may terminate our existing purchase orders and future business relationship with the Vendor.

Certifications: We expect and rely on our Vendors to comply with our Vendor Compliance Requirements and all applicable laws and regulations and provide us with merchandise that is fully compliant with these requirements, including all laws prohibiting slavery, human trafficking, and child labor. Our “Vendor On-Boarding” process requires our Vendors to certify that they will comply with our Vendor Compliance Requirements and all applicable laws and regulations. Our Vendors or their factories of private label and licensed brand goods sourced and imported by us are required to complete and supply a manufacturer certificate with each shipment, certifying they do not participate in slavery, human trafficking, and child labor and that the materials used in the products purchased by us comply with the laws regarding slavery, human trafficking, and child labor of the country or countries where the Vendors do business. Purchase orders are governed by our Terms and Conditions of Purchase, pursuant to which each of our Vendors must validate that their merchandise was not produced using any child, slave, prison or forced labor or any factory involved with human trafficking and that the Vendor complies with applicable legal requirements. By accepting one of our purchase orders, each Vendor certifies to us that they are in compliance with our Terms and Conditions of Purchase, including their prohibition of slavery, human trafficking, and child labor. We may take several types of actions against Vendors found to be in violation of our Vendor Compliance Requirements, including but not limited to canceling purchase orders, severing our business relationship with the Vendor, reporting the Vendor to the appropriate authorities, and seeking indemnity and/or damages.

Internal Accountability: Our associates are required to comply with our Vendor Compliance Requirements and all laws and regulations applicable to our business, including the sourcing of our goods. Our associates are required to ensure that our own labor and hiring practices are free from slavery, human trafficking, and child labor and report any potential or actual noncompliance with our Vendor Compliance Requirements by our associates. Our associates are further required to ensure that all of our Vendors and their factories comply with our Vendor Compliance Requirements and all applicable laws, and report any potential or actual noncompliance of these requirements and laws by our Vendors and their factories. Associates found to be in violation of these requirements are subject to corrective action up to and including termination of their employment.

Training: We provide training to our associates on our Ethics and Code of Conduct Policy. Relevant associates involved in our supply chain operations receive ethics training via written communications, materials, webinars and internal/external seminars.

For any questions or concerns regarding our Vendor Compliance Requirements or our compliance with the California Transparency in Supply Chains Act, please contact our Legal Department at 1800 N. Mason Road, Katy, Texas 77449 or by email at legal@academy.com.