California Transparency in
Supply Chains Act (SB657)

Tiffany & Co. has a supply chain auditing program. This program addresses the risks of human trafficking and slavery for suppliers in the Social Accountability Program. Our audits are conducted both internally and by a third party. Third-party verification is required of all of our high-risk suppliers in the Social Accountability Program, determined by a review of the vendor’s self-assessment, industry and geographic location.

Audits are conducted to evaluate compliance with the Tiffany & Co. Vendor Code of Conduct as well as local and international labor laws and regulations.

When a vendor fails to meet Tiffany & Co. requirements, every effort is made to work with that vendor to implement corrective action. If the vendor still fails to meet our requirements, the relationship may be terminated.

Tiffany & Co. supply chain management has received training on our Social Accountability Program, which includes mitigating risks of human trafficking and slavery within our supply chain. We require all employees who work on supply chain management to understand Tiffany & Co.’s Social Accountability Program and Vendor Code of Conduct. As with all alleged violations of policy, employees are trained to investigate issues and take appropriate action up to and including terminating agreements with vendors who have demonstrated egregious or uncorrected material violations.