C-TPAT POLICY: Factory Minimum Security Guidelines

As a participant in the Customs-Trade Partnership Against Terrorism (C-TPAT), Eddie

Bauer is committed to taking steps to prevent unknown infiltration of dangerous
materials into shipments of Eddie Bauer products. While our C-TPAT program
encompasses the entire supply chain, these Security Guidelines provide specific
requirements for all factories that produce goods – or prepare goods for shipment
(together, referred to in these Guidelines as “Factories”) – for Eddie Bauer LLC or Eddie
Bauer of Canada Corporation.

We encourage all of our supply chain partners – including Factories – to continuously

improve supply chain security. All supply chain partners are encouraged to maintain a
current understanding of C-TPAT requirements under the C-TPAT program through
regular review of the US Customs Border Protection website
http://www.cbp.gov/xp/cgov/trade/cargosecurity/ctpat In addition, Factories should
consider – and implement where possible – best practices including those identified on
the CBP website - http://www.cbp.gov/linkhandler/cgov/trade/cargo security/ctpat/ctpat
members/ct patbestpractices.ctt/ctpatbestpractices.pdf.

These Factory Security Guidelines set the minimum requirements related to facility
security that all Factories must meet to do business with Eddie Bauer.

A. Building and Yard Security

Security starts with making your buildings, parking lots and yards secure, to deter
unauthorized persons from accessing sensitive areas of your factory.
1. Maintain a secure perimeter at the facility – this means:
 a regularly inspected and maintained wall or fence
 which is at least 6 feet high and
 is topped by a deterrent including (but not limited to) barbed or razor wire;
OR
 you have a continuously operating – i.e., 24 hours per day 7 days per week –
electronic alarm system; OR
 or you have security guards continuously – i.e., 24 hours per day 7 days
per week – patrolling the perimeter.
 walls/fences are maintained by periodic inspection and repair to prevent
unauthorized access. A maintenance log should be maintained showing the date
and time of each inspection, any issues shown by the inspection, and the date the
issues were corrected.

2.. Have working locking devices on all outside gates, windows and doors providing
access into the packing, shipping or receiving areas. These should be regularly
inspected and promptly repaired if not in good working condition.

3. Maintain exterior lighting covering all:

 facility entrances and exits;
 cargo handling areas;
 cargo storage areas;
  - parking areas that are located in the proximity of the shipping and
receiving area;
 perimeter fences.

4. Maintain adequate interior lighting in the packing, shipping and receiving

areas.

5. Separate your packing areas from the manufacturing, shipping, and receiving areas,
and segregate packed cargo in a secure area.

6. Ensure all containers – both empty and full – are kept in a secure area, and
inspect all containers before use using a 7-point inspection (see provided
procedure).

7. Separate parking areas for employees and visitors away from the cargo
shipping/receiving areas.

8. Staff or monitor all gates through which vehicles enter or exit. Log all entries.

9. Ensure that all visitors

 are required to present valid identification and
 are recorded in a visitor log upon arrival at the factory
 provided with Visitor’s Badges that must be worn at all times while in the
factory
 are escorted by authorized employees
 have all bags searched before entry

Ensure that unidentified or unauthorized individuals are immediately reported to

security. Upon notification, factory security personnel will immediately ensure
individuals are identified as required above, or escorted from the factory or from
the secure area.

10. Ensure that all employees

 are required to present valid identification prior to their entrance into the
facility.
 have their bags inspected prior to their entrance into the factory.
 have limited access to packing, shipping and receiving areas - only assigned
and authorized employees can access.

B. Personnel Security
If your factory personnel cannot be trusted, you cannot keep your facilities
secure. Some basic precautions that help you ensure that your employees can
be trusted to help you maintain security are:
 pre-screen prospective employees for positions in the packing,
shipping, or receiving areas. Verify their prior employment and that
they were not terminated for any issues of honesty.
 perform background checks – where permitted by local law – as part of the
pre-screening of all prospective facility security employees AND
management employees in the packing, shipping, or receiving areas.
  provide Employee Identification Badges – including a photo of the
employee, and will require Employee ID badges be worn by all employees
within the factory at all times.
 ensure Employee Identification Badges and access keys are retrieved from
terminated employees no later than the date of termination.
 If you have regular contractors working at your facility, issue them
separate photo i.d. badges of a different color so that they can be easily
identified as contractors.
 Require that any business partner supplying personnel to work in your
factory conducts a background check and prior employment verification
of each person assigned to work in your factory.

C. Procedural Security
Having written processes that clearly define what your security expectations are will
assist you in maintaining a secure facility.
1. Designate qualified personnel responsible for the
implementation of the Factory’s Security Policies and Procedures.

2. Establish written security policy and procedures. Security Policies and

Procedures for Factories will include protocols for reporting abnormalities from the
factory to local government or enforcement agencies

3. Provide new hire and annual training on security and require all
employees to acknowledge in writing the Factory’s Security Policies and
Procedures.

4. Perform comprehensive security assessments on a periodic basis.

Make your employees a partner in ensuring a safe and secure factory by establishing a
threat awareness program to foster awareness among all employees of supply chain
security threats, and how to respond to violations of your policies.

D. Packing and Cargo Security

Protecting your factory and goods during the packing/shipping process is CRITICAL to
ensuring that dangerous items are not included in your cartons/containers.
1. To ensure the security of the goods shipped, the factory must:
 Ensure packing is supervised by either security personnel or factory
management.
 Only allow authorized packing/shipping personnel into packing and
shipping areas.
 ensure all inbound and outbound cargo is inspected by either
security personnel or factory management.
 periodically screen arriving packages – including mail –before
distribution.
 ensure that the loading of containers and trucks is supervised by either
security personnel or factory management.
 ensure all outbound containers and trucks are sealed by either
security personnel or factory management. See below for discussion
on the use of seals.
  ensure all empty containers and trucks are inspected for damage and
contamination prior to loading. USE THE C-TPAT 7-POINT
EXAMINATION PROCESS!

 Front wall
 Left side
 Right side
 Ceiling/Roof
 Inside/Outside doors
 Outside/Undercarriage

2. Seals are a critical component for security!

 Adopt a seal policy – for Eddie Bauer’s seal policy, see
www.eddiebauerglobalsourcing.com – Vendor Set Up Documents – C-TPAT –
EB Seal Policy. Seals should not be issued in numeric order – all seals should be
randomly issued.
 Appoint a “Seal Compliance Officer” who holds the seals in a secure area and
places them on trucks and containers
 Use C-TPAT compliant seals on all trucks, and only ship in trucks that can be
sealed – open pickups or flatbed trucks ARE NOT COMPLIANT
 Maintain a record of all seal, container and truck numbers for inbound and
outbound cargo. Prepare your log by listing each seal number as you start a new
batch of seals, and then log the date of assignment and container number of each
seal issued. When a batch of seals is fully used, check your log to ensure that all
seals are accounted for.
 maintain a log of any tampering or issues with seals, and investigate and
resolve all issues. Report tampering with seals to local authorities where
appropriate.

F. Conveyance Security
Making sure your goods are not tampered with while being transported from your
factory to the port/consolidator is essential to maintaining security over those goods.
First, make sure that the truck is sealed with ISO seals as recommended by U.S.
Customs.
Second, maintain a list – including the name, address and security status – of the
trucking companies used to transport cargo to the consolidator, freight forwarder, port or
carrier, so if there ever is a problem, it can be traced back.
Third, require your driver to confirm safe arrival at port by cell phone.

G. Information Technology Security

Access to your internal computer systems need to be secured so that others cannot
modify carton counts on shipping documents, give loading dock access to unauthorized
personnel, or manipulate your security policies and procedures.
1. Factories will ensure access to information technology is limited to
authorized personnel through the use of individual accounts protected by passwords
which are changed periodically and immediately, upon the termination of an
authorized person with knowledge of the passwords.
2. Factories will ensure system access is removed for all terminated
employees on a timely basis.
3. Factories will have written Information Technology security policies and
 procedures which are provided to all employees with computer access.
Violation of the policies must result in disciplinary action, including
termination of employment where appropriate.
4. Factories will ensure all manifest information is legible, complete and accurate.

H. Business Partner Requirements

Eddie Bauer requires you to follow these Security Guidelines – and you must carefully
chose your business partners and ask that all of your business partners – trucking firms,
security firms, suppliers with access to your facilities – have security awareness, will
follow your policies, and partner with you to ensure your goods are secure. Each factory
must:
1. maintain written, verifiable processes for the selection of business partners
2. require business partners to demonstrate compliance with supply chain security
standards
3. conduct periodic reviews of business partners' processes and facilities based on
supply chain security related risk

J. Monitoring and Compliance

Eddie Bauer is required to ensure that the factories making its goods follow these
guidelines. For that reason, we may make announced and unannounced on-site
inspections of factories, to monitor compliance with the Factory Security Guidelines.

Factories must maintain on site all documentation necessary to demonstrate compliance

with the Factory Security Guidelines. Factories must allow our representatives full access
to factory premises, factory records and workers for confidential interviews in connection
with inspections.

Factories are expected to take necessary corrective actions to promptly remediate any
noncompliance with the Factory Security Guidelines. Eddie Bauer reserves the right to
terminate its business relationship with any Factory that is unwilling or unable to comply
with the Factory Security Guidelines.

Thank you.

Rev January 2015