The California Transparency in Supply Chains Act of 2010

This document describes The Gymboree Corporation’s (“Gymboree”) response to The California Transparency in Supply Chains Act of 2010. For additional information about our ongoing efforts to support human rights and fair labor practices at the factories that we contract with, please go to our Social Responsibility page.

Verification of the supply chain to evaluate and address risks of human trafficking and slavery

We are committed to making a difference inside and outside of our company, and this begins with giving kids a chance to be kids and producing quality products that make us proud.

Gymboree regularly monitors and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. Prior to sourcing products from new countries, our social compliance team evaluates the country for any known labor rights and human rights issues. Additionally, we collaborate with our third-party monitoring firms to further identify potential “high risk” issues, such as vendors that are operating in regions within countries that are known to have a high percentage of migrant/guest workers or debt bondage.

If any risks are identified, our social compliance team works directly with our Senior Vice President of Production to determine if we should proceed with sourcing from the new country.

Furthermore, our customs compliance team is responsible for ensuring that Gymboree abides by all importation laws, including the U.S. law that prohibits the importation of goods produced by forced labor or child labor. If forced or child labor were to be discovered at one of our vendor’s factories, Gymboree would not, in addition to seeking to remediate the situation, take possession of goods that were manufactured under these conditions

Audit of the supply chain to verify compliance with standards for human trafficking and slavery

Gymboree uses independent third party auditors to conduct unannounced social audits on all of our factories. Gymboree will not work with any factory that will not allow Gymboree’s third party auditors to conduct unannounced audits. All of our factories are required to comply with our Terms of Engagement and are responsible for ensuring that they meet or exceed each of our monitoring standards. During the audit, our auditors measure the factories against the Terms of Engagement.

Verification that suppliers of materials incorporated into Gymboree’s products comply with laws regarding human trafficking and slavery

In our Terms of Engagement, we require that our factories only source raw materials that are incorporated into our products from suppliers who comply with all applicable laws, including, without limitation, the laws regarding slavery and human trafficking.

Accountability Standard

In the event that we identify a potential violation of labor or human rights, Gymboree promptly addresses the issue with the factory and outlines specific steps for correcting the issue as defined in our remediation process. To date, we have never encountered a violation related to slavery or trafficking in our supply chain. In the event that we ever do identify a potential incident, we would implement our remediation process.

Training on human trafficking and slavery

Gymboree provided a training on human trafficking and slavery issues to our social compliance team and Senior Vice President of Production in December of 2011. In January of 2012, we will provide training to other Gymboree personnel who have direct responsibility for our global supply chain including our sourcing, quality and customs teams. Furthermore, we will incorporate information on the prohibition of human trafficking and slavery during the social responsibility portion of the onboarding of all new factories and agents.

The Gymboree Corporation is committed to upholding fair labor practices and human rights in every aspect of our supply chain. We will continue to enhance our social responsibility program as we learn from our experience on how to best address labor and human rights throughout our supply chain and we will continue to align our program with industry best practices, including in the areas of slavery and human trafficking.