California Transparency in Supply Chains Act of 2010 Disclosure

At Half Price Books our founders believed in addressing the “human quota, rather than just dollars and cents.” The founding spirit of activism and acceptance of all people remains in our company today. As a company, we understand the importance of eradicating slavery and human trafficking from every business enterprise, regardless of its location.

Half Price Books buys and sells anything printed or recorded except yesterday’s newspaper. Preserving and recycling resources and entertainment of every form is our business. In accordance with our mission, Half Price Books purchases a majority of its products directly from customers at over a hundred retail locations spread across the United States.

Verifications and Audits

In addition to purchasing used books and other items directly from customers, Half Price Books purchases new goods, including new books and other items, from brokers located primarily in the United States and the United Kingdom. Because of Half Price Books’ unique business model, primarily buying used books from customers, Half Price Books does not currently conduct verifications or audits of its suppliers. Half Price Books internally analyzed the risk of slavery and human trafficking in its supply chain and, based on the lack of risk from Half Price Books’ unique system of direct suppliers, determined that verifications and audits would be impractical and unnecessary at this time.

Certification

The company’s few overseas direct suppliers who manufacture new goods, including books and book-related items, have written environmental and social polices, including policies against forced labor and child labor. Half Price Books requires each of these suppliers to maintain written policies stating that their goods are made in compliance with international standards regarding slavery and human trafficking. Currently, each overseas direct supplier has promulgated written policies stating that employment is freely chosen and suppliers shall not use forced labor or child labor. Additionally, each supplier states in writing that it has sufficient systems to monitor compliance with social polices, conducts regular assessments to identify non-compliance, develops remediation plans to resolve non-compliance, and regularly monitors the effective implementation of remediation plans. Because Half Price Books is not aware of any suppliers that represent a risk of engaging in slavery or human trafficking, Half Price Books does not require that these suppliers separately “certify” their compliance.

Internal Accountability

Half Price Books’ employees and contractors with responsibility for supply chain management are expected to seek suppliers that comply with laws regarding slavery and human trafficking. An employee’s failure to meet these expectations would be addressed through discipline and/or additional training. Half Price Books is currently in the process of developing a comprehensive Supplier Code of Ethical Conduct.

Training

In order to raise internal awareness of slavery and human trafficking, Half Price Books utilized a third party training program to educate employees responsible for supply chain management on preventing slavery and human trafficking from the supply chain. In 2012, each employee responsible for supply chain management successfully completed third party training on awareness, identification, prevention, and remediation of slavery and human trafficking in supply chains.