Supplier Code of Conduct

At Trans World Entertainment Corporation, we strive to work with suppliers who treat their workers with dignity and respect, adhere to applicable laws and regulations, and make their products in an environmentally sustainable manner. Accordingly, we require each supplier providing us with products to comply with the following Supplier Code of Conduct (our "Code").

1. Forced Labor:
Suppliers must comply with all laws and regulations related to slavery and human trafficking in the countries in which they do business. Suppliers must ensure that (i) all work performed for them will be voluntary, (ii) their workers will be free to keep their own identification documents and to leave their positions at any time upon reasonable notice, (iii) they will not use forced, bonded, or indentured labor or involuntary prison labor, and (iv) they will not be involved in the recruitment, abduction, transport, harboring, transfer, sale, or receipt of persons through force, coercion, fraud, or deception. Suppliers must require the producers and providers of goods and materials used in products sold to Trans World Entertainment to comply with all of the foregoing requirements.

2. Child Labor:
Suppliers shall not employ people younger than 15, or the minimum age for the completion of compulsory education, or the minimum age of employment required by law in the country of manufacture, whichever is highest.

3. Harassment and Abuse:
Suppliers shall treat every employee with respect and dignity, and shall not subject any employee to physical, sexual, psychological, or verbal harassment or abuse.

4. Nondiscrimination:
Suppliers shall not subject any person to discrimination in employment (including hiring, salary benefits, advancement, discipline, termination, or retirement) on the basis of gender, marital status, race, religion, age, disability, sexual orientation, nationality, political opinion, social or ethnic origin or any other condition that could give rise to discrimination.

5. Health and Safety:
Suppliers shall provide a safe and healthy environment to prevent accidents and injury to health from occurring and comply with applicable laws and regulations. Suppliers shall identify, assess and minimize the impact of emergency situations by implementing emergency plans and response procedures. These plans and procedures must include the following: emergency exits are accessible and fully functional at all times, fire extinguishers must be visible, accessible, present and charged, evacuation plans must be posted and drills must be conducted annually. Supplier shall identify, evaluate and control exposure to hazards and ensure the use of any applicable personal protective equipment.

6. Freedom of Association and Collective Bargaining:
Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining. Management is encouraged to engage in direct communication with employees.

7. Wages and Benefits:
Suppliers shall pay employees at least the minimum wage required by local law, or the prevailing industry wage if no minimum wage law applies, and shall provide legally mandated employee benefits.

8. Hours of Work/Compensation:
Employees should not be required to work more than 60 hours a week, or the maximum number of work hours per week permitted in the applicable country of manufacture, whichever is less, except in extraordinary business circumstances. Employees should be granted at least one day off in every seven-day period. In addition to their compensation for regular hours of work, suppliers shall compensate employees for overtime hours and the applicable premium rate in their country. In countries that have not established premium overtime rates, suppliers shall not pay employees less than their regular hourly rate for overtime hours.

9. Ethical Standards:
Suppliers are held to the highest standards of integrity. Corruption, bribery and extortion are strictly prohibited. Suppliers must respect all intellectual property rights and applicable regulatory requirements of the countries from and to which they ship.

10. Environmental Impact:
Suppliers must meet all applicable environmental laws and regulations in their country to manage hazardous materials and all waste and emissions materials. In addition, Suppliers are encouraged to have environmental policies and environmental management systems containing goals with targets that are focused on the continuous improvement of overall environmental performance.

Monitoring and Compliance
Trans World Entertainment Corporation seeks relationships with suppliers that are committed to manufacturing products under fair and safe labor conditions and sound environmental practices. If we determine that a particular factory does not comply with our Code, we typically strive to work with the supplier encouraging them to develop and implement an acceptable code of basic working conditions. Trans World Entertainment Corporation may elect to end its relationship with any supplier at any time for failing to adhere to our Supplier Code of Conduct. Trans World Entertainment Corporation requests that its suppliers post the Supplier Code of Conduct in a place visible to employees, in their native language(s).

Trans World Entertainment

38 Corporate Circle, Albany, NY 12203 | P.O. Box 12-490, Albany, NY 12212