Supplier Code of Conduct

HELEN OF TROY LIMITED – PRIVACY POLICY- 9/29/17

WE VALUE THE TRUST YOU PLACE IN HELEN OF TROY AND/OR ITS AFFILIATES (REFERRED TO AS “HELEN OF TROY” OR “WE” OR “OUR”). WE WANT TO ENSURE THAT YOU UNDERSTAND WHAT INFORMATION WE GATHER ABOUT YOU, HOW WE USE IT, AND THE SAFEGUARDS WE HAVE IN PLACE IN ORDER TO PROTECT IT. IF YOU HAVE ADDITIONAL QUESTIONS OR WOULD LIKE FURTHER INFORMATION ON THIS TOPIC, PLEASE FEEL FREE TO CONTACT US: 1-800-487-7273 OR [email protected] (MAILTO: [email protected]).

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING THIS WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR WEBSITE. HELEN OF TROY MAY UPDATE THIS POLICY FROM TIME TO TIME. PLEASE VISIT THIS PAGE PERIODICALLY TO REVIEW THE PRIVACY POLICY. YOUR CONTINUED USE OF THIS WEBSITE AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES.

CHILDREN UNDER THE AGE OF 13

OUR WEBSITE IS NOT INTENDED FOR CHILDREN UNDER 13 YEARS OF AGE. NO ONE UNDER AGE 13 MAY PROVIDE ANY INFORMATION TO OR ON THE WEBSITE. WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13. IF YOU ARE UNDER 13, DO NOT USE OR PROVIDE ANY INFORMATION ON THIS WEBSITE OR ON OR THROUGH ANY OF ITS FEATURES, USE ANY OF THE INTERACTIVE OR PUBLIC COMMENT FEATURES OF THIS WEBSITE OR PROVIDE ANY INFORMATION ABOUT YOURSELF TO US, INCLUDING YOUR NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, OR ANY SCREEN NAME OR USER NAME YOU MAY USE. IF WE LEARN WE HAVE COLLECTED OR RECEIVED PERSONAL INFORMATION FROM A CHILD UNDER 13 WITHOUT VERIFICATION OF PARENTAL CONSENT, WE WILL DELETE THAT INFORMATION. IF YOU BELIEVE WE MIGHT HAVE ANY INFORMATION FROM OR ABOUT A CHILD UNDER 13, PLEASE CONTACT US AT THE NUMBER LISTED ABOVE.

HOW DOES HELEN OF TROY ENSURE THAT YOUR INFORMATION IS SECURE?

HELEN OF TROY WILL MAINTAIN PRACTICES AND PROCEDURES DESIGNED TO ENSURE THE SECURITY, INTEGRITY AND CONFIDENTIALITY OF CUSTOMER INFORMATION. WE RESTRICT AND LIMIT ACCESS TO CUSTOMER INFORMATION ONLY TO THOSE OF OUR EMPLOYEES OR AUTHORIZED SERVICE PROVIDERS WHO NEED IT TO CARRY OUT THEIR BUSINESS FUNCTIONS, AND EDUCATE OUR EMPLOYEES ABOUT SAFEGUARDING CUSTOMER INFORMATION AND PREVENTING ITS UNAUTHORIZED ACCESS, DISCLOSURE, OR USE. WHEN CREDIT CARD INFORMATION IS TRANSMITTED ONLINE, HELEN OF TROY USES INDUSTRY STANDARD SECURITY MEASURES CALLED SSL (SECURE SOCKET LAYER ENCRYPTION). WHILE HELEN OF TROY CURRENTLY DOES NOT COLLECT PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES, HELEN OF TROY ALSO DOES NOT RESPOND TO WEB BROWSER “DO NOT TRACK” SIGNALS OR OTHER MECHANISMS THAT PROVIDE CONSUMERS THE ABILITY TO EXERCISE CHOICE REGARDING THE COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES.

WHAT TYPE OF INFORMATION DOES HELEN OF TROY COLLECT?

HELEN OF TROY GATHERS CUSTOMER INFORMATION NEEDED TO PROVIDE SUPERIOR SERVICE, COMMUNICATE OFFERS ON MERCHANDISE AND SERVICES THAT WE BELIEVE WILL BE OF INTEREST TO YOU, AND TO ADMINISTER OUR BUSINESS. IN ORDER TO BEST SERVE YOU, WE MAY GATHER INFORMATION FROM YOU IN A FEW INSTANCES. FIRST, WHEN YOU VISIT OUR SITE, WE MAY COLLECT NON-PERSONALLY IDENTIFIABLE INFORMATION FROM YOU. THROUGH THE USE OF COMPUTER “COOKIES” (SMALL PIECES OF INFORMATION THAT ARE STORED BY THE BROWSER ON YOUR HARD DRIVE), WE COLLECT DATA, SUCH AS YOUR IP ADDRESS, BROWSER TYPE, DOMAIN NAME, AND SPECIFIC HELEN OF TROY WEB PAGES THROUGH WHICH YOU CLICK. THE COOKIES THAT ARE CONFIGURED BY US DO NOT CONTAIN ANY PERSONALLY IDENTIFYING INFORMATION, SUCH AS YOUR NAME, OR SENSITIVE INFORMATION, SUCH AS YOUR CREDIT CARD NUMBER. THIS DATA IS COLLECTED AUTOMATICALLY, AND UTILIZED IN AGGREGATE TO HELP US LOOK FOR TRENDS SO THAT WE CAN IMPROVE OUR WEBSITE AND YOUR HELEN OF TROY EXPERIENCE. THE COOKIES ALSO ALLOW US TO RECOGNIZE YOU WHEN YOU RETURN TO OUR SITE AND TO PROVIDE YOU WITH A CUSTOMIZED EXPERIENCE THAT WE FEEL WILL BE OF VALUE TO YOU. MOST WEB BROWSERS ALLOW YOU TO EXERCISE CONTROL OVER COOKIE FILES ON YOUR COMPUTER BY ERASING THEM, BLOCKING THEM, OR NOTIFYING YOU WHEN SUCH A FILE IS STORED. PLEASE TAKE A LOOK AT YOUR PARTICULAR BROWSER FOR INSTRUCTIONS ON THIS FUNCTION. IF YOU DO ELECT TO DISABLE THE HELEN OF TROY COOKIE, PLEASE NOTE THAT YOU MAY NOT BE ABLE TO TAKE FULL ADVANTAGE OF A PERSONALIZED EXPERIENCE AT HELEN OF TROY. SECOND, WE MAY ASK YOU TO VOLUNTARILY PROVIDE INFORMATION IN A FEW CIRCUMSTANCES. WHEN YOU PURCHASE ITEMS, WE WILL ASK YOU TO VOLUNTARILY PROVIDE CERTAIN PERSONALLY IDENTIFIABLE INFORMATION, SUCH AS, YOUR NAME, ADDRESS, TELEPHONE NUMBER, E-MAIL ADDRESS, AND CREDIT CARD NUMBER. WE NEED THIS INFORMATION TO PROCESS AND FULFILL YOUR ORDER AND NOTIFY YOU OF ORDER STATUS. OTHER EXAMPLES OF WHEN WE MAY ASK YOU TO VOLUNTARILY PROVIDE PERSONALLY IDENTIFIABLE INFORMATION INCLUDE IF YOU SUBSCRIBE TO OUR EMAIL PROGRAM (INFORMATION SUCH AS YOUR NAME AND E-MAIL ADDRESS), CHOOSE TO PROVIDE US PREFERENCE INFORMATION (SUCH AS INTERESTS, PRODUCT PREFERENCES, AND ITEMS PURCHASED), OR WHEN YOU ENTER A SWEEPSTAKES OR PROMOTION (INFORMATION SUCH AS NAME, ADDRESS AND TELEPHONE NUMBER). ADDITIONALLY, IN ORDER TO PROVIDE YOU WITH GOODS AND SERVICES DESIGNED TO MEET YOUR NEEDS, WE MAY COLLECT DEMOGRAPHIC INFORMATION (SUCH AS NUMBER OF HOUSEHOLD MEMBERS, AGE, AND GENDER), PURCHASE PREFERENCE INFORMATION, AND

MAILING LISTS FROM THIRD PARTIES. WE USE THIS INFORMATION TO CUSTOMIZE YOUR EXPERIENCE ON OUR WEBSITE AND TO PROVIDE YOU WITH THE MOST RELEVANT PRODUCTS AND SERVICES.

HELEN OF TROY ALSO USES GOOGLE ANALYTICS AND ADWORDS TO COMPILE INFORMATION COLLECTED VIA COOKIES IN A MANNER WHICH IS HELPFUL TO US IN ANALYZING VISITORS’ USE OF THE SITE. GOOGLE ANALYTICS ALSO USES THIS INFORMATION TO PLACE ADVERTISEMENTS FOR OUR PRODUCTS ON OTHER SITES THAT YOU VISIT AFTER YOU VISIT OUR WEBSITE. THESE ADVERTISEMENTS MAY BE BASED ON THE PAGES YOU VISITED DURING YOUR USE OF OUR WEBSITE. THIS INFORMATION MAY BE SHARED WITH OTHER ORGANIZATIONS SUCH AS ADVERTISERS AND OUR PARTNERS, WHO MIGHT USE IT WITH INFORMATION ABOUT HOW YOU USE OTHER WEBSITES, INCLUDING TO IDENTIFY SHARED INTERESTS AND BEHAVIORS ACROSS GROUPS OF USERS WHO VISIT OUR (AND OTHER) WEBSITE. TO LEARN MORE, VISIT “HOW GOOGLE USES DATA WHEN YOU USE OUR PARTNER SITES OR APPS.” USERS MAY OPT OUT OF GOOGLE’S USE OF COOKIES BY VISITING GOOGLE ANALYTICS OPT-OUT BROWSER ADD-ON. USERS MAY OPT OUT OF THIRD PARTY VENDOR USE OF THE COOKIES BY VISITING THE NETWORK ADVERTISING INITIATIVE OPT-OUT PAGE.

WHAT INFORMATION DO WE SHARE AND WITH WHOM?

HELEN OF TROY DOES NOT RENT OR SELL CUSTOMER INFORMATION TO OUTSIDE MARKETERS. IN CERTAIN CIRCUMSTANCES, HELEN OF TROY MAY SHARE YOUR CUSTOMER INFORMATION WITH OUR SUBSIDIARIES OR AFFILIATES OR TRUSTED SERVICE PROVIDERS THAT NEED ACCESS TO YOUR INFORMATION TO PROVIDE OPERATIONAL OR OTHER SUPPORT SERVICES. TO ENSURE THE CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION, SERVICE PROVIDERS MUST AGREE TO SAFEGUARD YOUR INFORMATION IN STRICT COMPLIANCE WITH OUR POLICY. WE ALSO MAY PROVIDE INFORMATION TO REGULATORY AUTHORITIES AND LAW ENFORCEMENT OFFICIALS IN ACCORDANCE WITH APPLICABLE LAW OR WHEN WE OTHERWISE BELIEVE IN GOOD FAITH THAT THE LAW REQUIRES IT. IN THE EVENT OF A SALE OF ALL OR PART OF ONE OF OUR BUSINESSES, WE MAY SHARE CUSTOMER INFORMATION RELATED TO THAT BUSINESS AS PART OF THE TRANSACTION.

HELEN OF TROY MAY DISCLOSE AGGREGATED INFORMATION ABOUT OUR USERS, AND INFORMATION THAT DOES NOT IDENTIFY ANY INDIVIDUAL, WITHOUT RESTRICTION.

CAN I “OPT OUT” OF RECEIVING PROMOTIONAL E-MAILS FROM HELEN OF TROY?

HELEN OF TROY MAY SEND YOU E-MAILS WITH PROMOTIONAL OFFERS. IF YOU WOULD NO LONGER LIKE TO RECEIVE E-MAILED SPECIAL EVENT INFORMATION, SALES NOTIFICATIONS OR OTHER MESSAGES FROM HELEN OF TROY, YOU MAY CONTACT US AT 1-800-487-7273 OR [email protected] (MAILTO:[email protected]) AND YOUR E-MAIL ADDRESS WILL BE REMOVED FROM OUR MARKETING LIST OR CLICK HERE TO FILL AN OPT OUT REQUEST FORM

HOW CAN I ACCESS MY HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE?

YOU CAN ACCESS YOUR HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE BY CONTACTING US AT 1-800-487-7273 OR [email protected] OR CLICK HERE TO FILL AN INFORMATION REQUEST FORM.

ALL WEBSITE DESIGN, GRAPHICS, TEXT SELECTIONS ARRANGEMENT, AND SOFTWARE ARE COPYRIGHT 2017, HELEN OF TROY ALL RIGHTS RESERVED.

All of Helen of Troy suppliers must comply with local legislation and regulations, and must conduct their activities, including those of their relevant subcontractors and vendors, in line with this Supplier Code of Conduct.

All suppliers are subject to environmental, social labor and human rights compliance audits, with all new suppliers being required to comply with such audits as part of the onboarding process. Suppliers are expected to designate management staff to monitor their relevant factories, production facilities, subcontractors, vendors, and compliance with our Supplier Code of Conduct. Helen of Troy may conduct announced or unannounced visits and/or have third-parties audit to ensure compliance with the Supplier Code of Conduct and all applicable laws and regulations. It is expected that suppliers provide Helen of Troy and its designated third-party auditors appropriate access, transparency, and documentation to enable the successful conduct of these audits. This access, transparency, and documentation include, without limitation, (1) the disclosure by the supplier of the identity, physical location and ownership of all factories and production facilities that produce or will produce goods for Helen of Troy, (2) causing the relevant factory, facility, subcontractor and sub-tier suppliers to provide the same level of access, transparency and documentation to Helen of Troy and its designated third-party auditors as required of the supplier, including access to buildings, facilities, records, and documentation, and (3) the ability of Helen of Troy and its designated third-party auditors to interview appropriate employees of the supplier, relevant factory, facility, subcontractor and sub-tier supplier. Any proposed changes from one facility to another or the use of sub-contractors must be approved in writing by Helen of Troy before any production begins.

The number of assessments conducted by Helen of Troy follows our risk-based approach and may be dependent on the level of project activity awarded throughout the year and the terms of our contract with the supplier. If gaps are identified, we endeavor to work with suppliers to help them understand how to close those gaps or we may ultimately consider terminating the contract. Suppliers that are required to develop a corrective action plan may be subject to additional audits, which may be announced or unannounced, as part of Helen of Troy’s monitoring efforts.

We are committed to engaging relevant stakeholders in the development, implementation, and evaluation of this Supplier Code of Conduct, taking into account international standards and guidelines such as the United Nations Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights and the International Labor Organization’s (ILO) Standards, including the ILO Declaration on Fundamental Principles and Rights at Work. We require our suppliers to respect these international standards and recognized guidelines, including those on human rights and other similar environmental and social topics.

We strive to include our Supplier Code of Conduct in relevant supplier contracts, where applicable. If permitted under our contract terms, we may seek to terminate contracts if suppliers breach Helen of Troy’s Supplier Code of Conduct.

HELEN OF TROY LIMITED – PRIVACY POLICY- 9/29/17

WE VALUE THE TRUST YOU PLACE IN HELEN OF TROY AND/OR ITS AFFILIATES (REFERRED TO AS “HELEN OF TROY” OR “WE” OR “OUR”). WE WANT TO ENSURE THAT YOU UNDERSTAND WHAT INFORMATION WE GATHER ABOUT YOU, HOW WE USE IT, AND THE SAFEGUARDS WE HAVE IN PLACE IN ORDER TO PROTECT IT. IF YOU HAVE ADDITIONAL QUESTIONS OR WOULD LIKE FURTHER INFORMATION ON THIS TOPIC, PLEASE FEEL FREE TO CONTACT US: 1-800-487-7273 OR [email protected] (MAILTO: [email protected]).

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING THIS WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR WEBSITE. HELEN OF TROY MAY UPDATE THIS POLICY FROM TIME TO TIME. PLEASE VISIT THIS PAGE PERIODICALLY TO REVIEW THE PRIVACY POLICY. YOUR CONTINUED USE OF THIS WEBSITE AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES.

CHILDREN UNDER THE AGE OF 13

OUR WEBSITE IS NOT INTENDED FOR CHILDREN UNDER 13 YEARS OF AGE. NO ONE UNDER AGE 13 MAY PROVIDE ANY INFORMATION TO OR ON THE WEBSITE. WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13. IF YOU ARE UNDER 13, DO NOT USE OR PROVIDE ANY INFORMATION ON THIS WEBSITE OR ON OR THROUGH ANY OF ITS FEATURES, USE ANY OF THE INTERACTIVE OR PUBLIC COMMENT FEATURES OF THIS WEBSITE OR PROVIDE ANY INFORMATION ABOUT YOURSELF TO US, INCLUDING YOUR NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, OR ANY SCREEN NAME OR USER NAME YOU MAY USE. IF WE LEARN WE HAVE COLLECTED OR RECEIVED PERSONAL INFORMATION FROM A CHILD UNDER 13 WITHOUT VERIFICATION OF PARENTAL CONSENT, WE WILL DELETE THAT INFORMATION. IF YOU BELIEVE WE MIGHT HAVE ANY INFORMATION FROM OR ABOUT A CHILD UNDER 13, PLEASE CONTACT US AT THE NUMBER LISTED ABOVE.

HOW DOES HELEN OF TROY ENSURE THAT YOUR INFORMATION IS SECURE?

HELEN OF TROY WILL MAINTAIN PRACTICES AND PROCEDURES DESIGNED TO ENSURE THE SECURITY, INTEGRITY AND CONFIDENTIALITY OF CUSTOMER INFORMATION. WE RESTRICT AND LIMIT ACCESS TO CUSTOMER INFORMATION ONLY TO THOSE OF OUR EMPLOYEES OR AUTHORIZED SERVICE PROVIDERS WHO NEED IT TO CARRY OUT THEIR BUSINESS FUNCTIONS, AND EDUCATE OUR EMPLOYEES ABOUT SAFEGUARDING CUSTOMER INFORMATION AND PREVENTING ITS UNAUTHORIZED ACCESS, DISCLOSURE, OR USE. WHEN CREDIT CARD INFORMATION IS TRANSMITTED ONLINE, HELEN OF TROY USES INDUSTRY STANDARD SECURITY MEASURES CALLED SSL (SECURE SOCKET LAYER ENCRYPTION). WHILE HELEN OF TROY CURRENTLY DOES NOT COLLECT PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES, HELEN OF TROY ALSO DOES NOT RESPOND TO WEB BROWSER “DO NOT TRACK” SIGNALS OR OTHER MECHANISMS THAT PROVIDE CONSUMERS THE ABILITY TO EXERCISE CHOICE REGARDING THE COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES.

WHAT TYPE OF INFORMATION DOES HELEN OF TROY COLLECT?

HELEN OF TROY GATHERS CUSTOMER INFORMATION NEEDED TO PROVIDE SUPERIOR SERVICE, COMMUNICATE OFFERS ON MERCHANDISE AND SERVICES THAT WE BELIEVE WILL BE OF INTEREST TO YOU, AND TO ADMINISTER OUR BUSINESS. IN ORDER TO BEST SERVE YOU, WE MAY GATHER INFORMATION FROM YOU IN A FEW INSTANCES. FIRST, WHEN YOU VISIT OUR SITE, WE MAY COLLECT NON-PERSONALLY IDENTIFIABLE INFORMATION FROM YOU. THROUGH THE USE OF COMPUTER “COOKIES” (SMALL PIECES OF INFORMATION THAT ARE STORED BY THE BROWSER ON YOUR HARD DRIVE), WE COLLECT DATA, SUCH AS YOUR IP ADDRESS, BROWSER TYPE, DOMAIN NAME, AND SPECIFIC HELEN OF TROY WEB PAGES THROUGH WHICH YOU CLICK. THE COOKIES THAT ARE CONFIGURED BY US DO NOT CONTAIN ANY PERSONALLY IDENTIFYING INFORMATION, SUCH AS YOUR NAME, OR SENSITIVE INFORMATION, SUCH AS YOUR CREDIT CARD NUMBER. THIS DATA IS COLLECTED AUTOMATICALLY, AND UTILIZED IN AGGREGATE TO HELP US LOOK FOR TRENDS SO THAT WE CAN IMPROVE OUR WEBSITE AND YOUR HELEN OF TROY EXPERIENCE. THE COOKIES ALSO ALLOW US TO RECOGNIZE YOU WHEN YOU RETURN TO OUR SITE AND TO PROVIDE YOU WITH A CUSTOMIZED EXPERIENCE THAT WE FEEL WILL BE OF VALUE TO YOU. MOST WEB BROWSERS ALLOW YOU TO EXERCISE CONTROL OVER COOKIE FILES ON YOUR COMPUTER BY ERASING THEM, BLOCKING THEM, OR NOTIFYING YOU WHEN SUCH A FILE IS STORED. PLEASE TAKE A LOOK AT YOUR PARTICULAR BROWSER FOR INSTRUCTIONS ON THIS FUNCTION. IF YOU DO ELECT TO DISABLE THE HELEN OF TROY COOKIE, PLEASE NOTE THAT YOU MAY NOT BE ABLE TO TAKE FULL ADVANTAGE OF A PERSONALIZED EXPERIENCE AT HELEN OF TROY. SECOND, WE MAY ASK YOU TO VOLUNTARILY PROVIDE INFORMATION IN A FEW CIRCUMSTANCES. WHEN YOU PURCHASE ITEMS, WE WILL ASK YOU TO VOLUNTARILY PROVIDE CERTAIN PERSONALLY IDENTIFIABLE INFORMATION, SUCH AS, YOUR NAME, ADDRESS, TELEPHONE NUMBER, E-MAIL ADDRESS, AND CREDIT CARD NUMBER. WE NEED THIS INFORMATION TO PROCESS AND FULFILL YOUR ORDER AND NOTIFY YOU OF ORDER STATUS. OTHER EXAMPLES OF WHEN WE MAY ASK YOU TO VOLUNTARILY PROVIDE PERSONALLY IDENTIFIABLE INFORMATION INCLUDE IF YOU SUBSCRIBE TO OUR EMAIL PROGRAM (INFORMATION SUCH AS YOUR NAME AND E-MAIL ADDRESS), CHOOSE TO PROVIDE US PREFERENCE INFORMATION (SUCH AS INTERESTS, PRODUCT PREFERENCES, AND ITEMS PURCHASED), OR WHEN YOU ENTER A SWEEPSTAKES OR PROMOTION (INFORMATION SUCH AS NAME, ADDRESS AND TELEPHONE NUMBER). ADDITIONALLY, IN ORDER TO PROVIDE YOU WITH GOODS AND SERVICES DESIGNED TO MEET YOUR NEEDS, WE MAY COLLECT DEMOGRAPHIC INFORMATION (SUCH AS NUMBER OF HOUSEHOLD MEMBERS, AGE, AND GENDER), PURCHASE PREFERENCE INFORMATION, AND

MAILING LISTS FROM THIRD PARTIES. WE USE THIS INFORMATION TO CUSTOMIZE YOUR EXPERIENCE ON OUR WEBSITE AND TO PROVIDE YOU WITH THE MOST RELEVANT PRODUCTS AND SERVICES.

HELEN OF TROY ALSO USES GOOGLE ANALYTICS AND ADWORDS TO COMPILE INFORMATION COLLECTED VIA COOKIES IN A MANNER WHICH IS HELPFUL TO US IN ANALYZING VISITORS’ USE OF THE SITE. GOOGLE ANALYTICS ALSO USES THIS INFORMATION TO PLACE ADVERTISEMENTS FOR OUR PRODUCTS ON OTHER SITES THAT YOU VISIT AFTER YOU VISIT OUR WEBSITE. THESE ADVERTISEMENTS MAY BE BASED ON THE PAGES YOU VISITED DURING YOUR USE OF OUR WEBSITE. THIS INFORMATION MAY BE SHARED WITH OTHER ORGANIZATIONS SUCH AS ADVERTISERS AND OUR PARTNERS, WHO MIGHT USE IT WITH INFORMATION ABOUT HOW YOU USE OTHER WEBSITES, INCLUDING TO IDENTIFY SHARED INTERESTS AND BEHAVIORS ACROSS GROUPS OF USERS WHO VISIT OUR (AND OTHER) WEBSITE. TO LEARN MORE, VISIT “HOW GOOGLE USES DATA WHEN YOU USE OUR PARTNER SITES OR APPS.” USERS MAY OPT OUT OF GOOGLE’S USE OF COOKIES BY VISITING GOOGLE ANALYTICS OPT-OUT BROWSER ADD-ON. USERS MAY OPT OUT OF THIRD PARTY VENDOR USE OF THE COOKIES BY VISITING THE NETWORK ADVERTISING INITIATIVE OPT-OUT PAGE.

WHAT INFORMATION DO WE SHARE AND WITH WHOM?

HELEN OF TROY DOES NOT RENT OR SELL CUSTOMER INFORMATION TO OUTSIDE MARKETERS. IN CERTAIN CIRCUMSTANCES, HELEN OF TROY MAY SHARE YOUR CUSTOMER INFORMATION WITH OUR SUBSIDIARIES OR AFFILIATES OR TRUSTED SERVICE PROVIDERS THAT NEED ACCESS TO YOUR INFORMATION TO PROVIDE OPERATIONAL OR OTHER SUPPORT SERVICES. TO ENSURE THE CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION, SERVICE PROVIDERS MUST AGREE TO SAFEGUARD YOUR INFORMATION IN STRICT COMPLIANCE WITH OUR POLICY. WE ALSO MAY PROVIDE INFORMATION TO REGULATORY AUTHORITIES AND LAW ENFORCEMENT OFFICIALS IN ACCORDANCE WITH APPLICABLE LAW OR WHEN WE OTHERWISE BELIEVE IN GOOD FAITH THAT THE LAW REQUIRES IT. IN THE EVENT OF A SALE OF ALL OR PART OF ONE OF OUR BUSINESSES, WE MAY SHARE CUSTOMER INFORMATION RELATED TO THAT BUSINESS AS PART OF THE TRANSACTION.

HELEN OF TROY MAY DISCLOSE AGGREGATED INFORMATION ABOUT OUR USERS, AND INFORMATION THAT DOES NOT IDENTIFY ANY INDIVIDUAL, WITHOUT RESTRICTION.

CAN I “OPT OUT” OF RECEIVING PROMOTIONAL E-MAILS FROM HELEN OF TROY?

HELEN OF TROY MAY SEND YOU E-MAILS WITH PROMOTIONAL OFFERS. IF YOU WOULD NO LONGER LIKE TO RECEIVE E-MAILED SPECIAL EVENT INFORMATION, SALES NOTIFICATIONS OR OTHER MESSAGES FROM HELEN OF TROY, YOU MAY CONTACT US AT 1-800-487-7273 OR [email protected] (MAILTO:[email protected]) AND YOUR E-MAIL ADDRESS WILL BE REMOVED FROM OUR MARKETING LIST OR CLICK HERE TO FILL AN OPT OUT REQUEST FORM

HOW CAN I ACCESS MY HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE?

YOU CAN ACCESS YOUR HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE BY CONTACTING US AT 1-800-487-7273 OR [email protected] OR CLICK HERE TO FILL AN INFORMATION REQUEST FORM.

ALL WEBSITE DESIGN, GRAPHICS, TEXT SELECTIONS ARRANGEMENT, AND SOFTWARE ARE COPYRIGHT 2017, HELEN OF TROY ALL RIGHTS RESERVED.

Promoting Ethical Conduct

We adhere to a high standard of ethical behavior as outlined in both our Code of Conduct and ESG Guiding Principles, and expect that our suppliers do the same. Our suppliers must conduct business in a legal and ethical manner. Suppliers must comply with all applicable local and national laws and regulations of the jurisdictions in which they are doing business. Where industry practices exceed legal requirements, preference will be given to suppliers who meet such industry practices. Our suppliers are prohibited from offering or accepting bribes or kickbacks in any form directly or indirectly to or from our representatives, government officials, or any third parties and must comply with all applicable laws and requirements relating to anti-bribery, anti-corruption, and similar legislation.

No Tolerance for-Child Labor

We are opposed to all forms of child labor. Our suppliers must only employ people who (a) meet the local legal minimum age for employment; (b) meet the age for completing compulsory education in the country of manufacture; or (c) are at least 15 years old, whichever is highest. Additionally, suppliers must not expose anyone under the age of 18 to work which, by its nature of the circumstances in which it is carried out, is likely to harm their health, safety, or morals.

Freely Chosen Labor

All of our supplier’s employees must be employed of their own volition, and by their own choice. Our suppliers must never use forced labor, whether in the form of restriction of movement, abuse of vulnerability, debt bondage, isolation, retention of identity documents, deception, abusive working & living conditions, prison labor, physical and sexual violence, excessive overtime, intimidation and threats; withholding of wage or any other form of compulsory labor.

Proactive Non-Discrimination

We are committed to creating a diverse and inclusive environment that welcomes and values our differences and expect our supplier partners to do the same. We expect that our suppliers hire, retain, train, promote and compensate without regard to race, color, sex, age, religion, creed, national origin, disability, genetic information, citizenship, uniform service member status, pregnancy, marital status, sexual orientation, gender expression and gender identity or other protected characteristics as established by law.

Freedom of Association and Collective Bargaining

We believe in the freedom of employees to organize as provided by law. Our suppliers must recognize and respect the right of employees to associate, organize and bargain collectively as provided by the law and do so in a peaceful manner without penalty or interference. Our suppliers must not interfere with, obstruct, or prevent or penalize such legitimate activities.

Protecting Migrant Workers

We forbid all forms of human trafficking and require the same of our supplier partners to assure prevention of human trafficking and ensure fair treatment of migrant workers, especially protection of the rights of those from vulnerable groups such as minorities and women. Our suppliers must have a written policy regarding their treatment of migrant workers and keep proper documentation, including, at a minimum, the requirements of fair treatment, non-retention of identity documents, the non-payment of recruitment fees, payment of transportation costs, repatriation, and any other relevant legal requirements. Our suppliers are expected to effectively communicate in migrant worker’s local language its migrant worker policy to relevant employees so that they are aware of their rights.

Preventing Harassment or Abuse

We are opposed to any form of workplace harassment or abuse. Our suppliers must treat all employees with respect and provide work environments that are free of physical, sexual, psychological, and verbal harassment and abuse, retribution for grievances, and corporal punishment. Suppliers shall have effective, confidential grievance mechanisms, to ensure that workers can raise issues without intimidation or fear of retaliation, and with applicable legal protections.

Fairness in Wages and Benefits

We pay our employees fair and legal wages and require that our supplier partners do the same. Our suppliers must pay each employee at least the minimum wage required by law and applicable premium rate for overtime and must provide all legally mandated benefits. Supplier must also provide employees with a clear written accounting for every pay period and must not deduct or withhold wages or benefits for disciplinary infractions.

Reasonable Hours of Work

We promote humane work hours. Our suppliers must comply with applicable laws and regulations regarding work hours, including the provision of appropriate number of rest hours and days and must operate in a manner that promotes humane and productive hours of work and working conditions. A minimum of one day of rest for every seven-day period is required. In addition, all overtime must be voluntarily agreed by suppliers’ employees and not excessive.

Mandating Occupational Health and Safety

We mandate a safe and healthy work environment and require that our supplier partners do the same. Our suppliers must provide safe work environments, complying with applicable laws and regulations regarding occupational health and safety and working conditions, including any housing and cafeteria requirements, and must provide a safe and healthy working environment to avoid work- related injuries and illnesses and promote the general health of employees.

Environmental Responsibility

We work toward minimizing our impact on the environment, including mitigating, and adapting to climate change, and require that our suppliers do the same. Our suppliers must comply with applicable environmental protection laws, must maintain a written environmental policy, and must implement a system to minimize or eliminate negative impacts of its practices on the environment. We work with our suppliers to reduce excessive packaging and to use recycled and low-impact materials, with the goal of on-going investigation and iterative improvement.

November 1, 2023

HELEN OF TROY LIMITED – PRIVACY POLICY- 9/29/17

WE VALUE THE TRUST YOU PLACE IN HELEN OF TROY AND/OR ITS AFFILIATES (REFERRED TO AS “HELEN OF TROY” OR “WE” OR “OUR”). WE WANT TO ENSURE THAT YOU UNDERSTAND WHAT INFORMATION WE GATHER ABOUT YOU, HOW WE USE IT, AND THE SAFEGUARDS WE HAVE IN PLACE IN ORDER TO PROTECT IT. IF YOU HAVE ADDITIONAL QUESTIONS OR WOULD LIKE FURTHER INFORMATION ON THIS TOPIC, PLEASE FEEL FREE TO CONTACT US: 1-800-487-7273 OR [email protected] (MAILTO: [email protected]).

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING THIS WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR WEBSITE. HELEN OF TROY MAY UPDATE THIS POLICY FROM TIME TO TIME. PLEASE VISIT THIS PAGE PERIODICALLY TO REVIEW THE PRIVACY POLICY. YOUR CONTINUED USE OF THIS WEBSITE AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES.

CHILDREN UNDER THE AGE OF 13

OUR WEBSITE IS NOT INTENDED FOR CHILDREN UNDER 13 YEARS OF AGE. NO ONE UNDER AGE 13 MAY PROVIDE ANY INFORMATION TO OR ON THE WEBSITE. WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13. IF YOU ARE UNDER 13, DO NOT USE OR PROVIDE ANY INFORMATION ON THIS WEBSITE OR ON OR THROUGH ANY OF ITS FEATURES, USE ANY OF THE INTERACTIVE OR PUBLIC COMMENT FEATURES OF THIS WEBSITE OR PROVIDE ANY INFORMATION ABOUT YOURSELF TO US, INCLUDING YOUR NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, OR ANY SCREEN NAME OR USER NAME YOU MAY USE. IF WE LEARN WE HAVE COLLECTED OR RECEIVED PERSONAL INFORMATION FROM A CHILD UNDER 13 WITHOUT VERIFICATION OF PARENTAL CONSENT, WE WILL DELETE THAT INFORMATION. IF YOU BELIEVE WE MIGHT HAVE ANY INFORMATION FROM OR ABOUT A CHILD UNDER 13, PLEASE CONTACT US AT THE NUMBER LISTED ABOVE.

HOW DOES HELEN OF TROY ENSURE THAT YOUR INFORMATION IS SECURE?

HELEN OF TROY WILL MAINTAIN PRACTICES AND PROCEDURES DESIGNED TO ENSURE THE SECURITY, INTEGRITY AND CONFIDENTIALITY OF CUSTOMER INFORMATION. WE RESTRICT AND LIMIT ACCESS TO CUSTOMER INFORMATION ONLY TO THOSE OF OUR EMPLOYEES OR AUTHORIZED SERVICE PROVIDERS WHO NEED IT TO CARRY OUT THEIR BUSINESS FUNCTIONS, AND EDUCATE OUR EMPLOYEES ABOUT SAFEGUARDING CUSTOMER INFORMATION AND PREVENTING ITS UNAUTHORIZED ACCESS, DISCLOSURE, OR USE. WHEN CREDIT CARD INFORMATION IS TRANSMITTED ONLINE, HELEN OF TROY USES INDUSTRY STANDARD SECURITY MEASURES CALLED SSL (SECURE SOCKET LAYER ENCRYPTION). WHILE HELEN OF TROY CURRENTLY DOES NOT COLLECT PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES, HELEN OF TROY ALSO DOES NOT RESPOND TO WEB BROWSER “DO NOT TRACK” SIGNALS OR OTHER MECHANISMS THAT PROVIDE CONSUMERS THE ABILITY TO EXERCISE CHOICE REGARDING THE COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEB SITES OR ONLINE SERVICES.

WHAT TYPE OF INFORMATION DOES HELEN OF TROY COLLECT?

HELEN OF TROY GATHERS CUSTOMER INFORMATION NEEDED TO PROVIDE SUPERIOR SERVICE, COMMUNICATE OFFERS ON MERCHANDISE AND SERVICES THAT WE BELIEVE WILL BE OF INTEREST TO YOU, AND TO ADMINISTER OUR BUSINESS. IN ORDER TO BEST SERVE YOU, WE MAY GATHER INFORMATION FROM YOU IN A FEW INSTANCES. FIRST, WHEN YOU VISIT OUR SITE, WE MAY COLLECT NON-PERSONALLY IDENTIFIABLE INFORMATION FROM YOU. THROUGH THE USE OF COMPUTER “COOKIES” (SMALL PIECES OF INFORMATION THAT ARE STORED BY THE BROWSER ON YOUR HARD DRIVE), WE COLLECT DATA, SUCH AS YOUR IP ADDRESS, BROWSER TYPE, DOMAIN NAME, AND SPECIFIC HELEN OF TROY WEB PAGES THROUGH WHICH YOU CLICK. THE COOKIES THAT ARE CONFIGURED BY US DO NOT CONTAIN ANY PERSONALLY IDENTIFYING INFORMATION, SUCH AS YOUR NAME, OR SENSITIVE INFORMATION, SUCH AS YOUR CREDIT CARD NUMBER. THIS DATA IS COLLECTED AUTOMATICALLY, AND UTILIZED IN AGGREGATE TO HELP US LOOK FOR TRENDS SO THAT WE CAN IMPROVE OUR WEBSITE AND YOUR HELEN OF TROY EXPERIENCE. THE COOKIES ALSO ALLOW US TO RECOGNIZE YOU WHEN YOU RETURN TO OUR SITE AND TO PROVIDE YOU WITH A CUSTOMIZED EXPERIENCE THAT WE FEEL WILL BE OF VALUE TO YOU. MOST WEB BROWSERS ALLOW YOU TO EXERCISE CONTROL OVER COOKIE FILES ON YOUR COMPUTER BY ERASING THEM, BLOCKING THEM, OR NOTIFYING YOU WHEN SUCH A FILE IS STORED. PLEASE TAKE A LOOK AT YOUR PARTICULAR BROWSER FOR INSTRUCTIONS ON THIS FUNCTION. IF YOU DO ELECT TO DISABLE THE HELEN OF TROY COOKIE, PLEASE NOTE THAT YOU MAY NOT BE ABLE TO TAKE FULL ADVANTAGE OF A PERSONALIZED EXPERIENCE AT HELEN OF TROY. SECOND, WE MAY ASK YOU TO VOLUNTARILY PROVIDE INFORMATION IN A FEW CIRCUMSTANCES. WHEN YOU PURCHASE ITEMS, WE WILL ASK YOU TO VOLUNTARILY PROVIDE CERTAIN PERSONALLY IDENTIFIABLE INFORMATION, SUCH AS, YOUR NAME, ADDRESS, TELEPHONE NUMBER, E-MAIL ADDRESS, AND CREDIT CARD NUMBER. WE NEED THIS INFORMATION TO PROCESS AND FULFILL YOUR ORDER AND NOTIFY YOU OF ORDER STATUS. OTHER EXAMPLES OF WHEN WE MAY ASK YOU TO VOLUNTARILY PROVIDE PERSONALLY IDENTIFIABLE INFORMATION INCLUDE IF YOU SUBSCRIBE TO OUR EMAIL PROGRAM (INFORMATION SUCH AS YOUR NAME AND E-MAIL ADDRESS), CHOOSE TO PROVIDE US PREFERENCE INFORMATION (SUCH AS INTERESTS, PRODUCT PREFERENCES, AND ITEMS PURCHASED), OR WHEN YOU ENTER A SWEEPSTAKES OR PROMOTION (INFORMATION SUCH AS NAME, ADDRESS AND TELEPHONE NUMBER). ADDITIONALLY, IN ORDER TO PROVIDE YOU WITH GOODS AND SERVICES DESIGNED TO MEET YOUR NEEDS, WE MAY COLLECT DEMOGRAPHIC INFORMATION (SUCH AS NUMBER OF HOUSEHOLD MEMBERS, AGE, AND GENDER), PURCHASE PREFERENCE INFORMATION, AND

MAILING LISTS FROM THIRD PARTIES. WE USE THIS INFORMATION TO CUSTOMIZE YOUR EXPERIENCE ON OUR WEBSITE AND TO PROVIDE YOU WITH THE MOST RELEVANT PRODUCTS AND SERVICES.

HELEN OF TROY ALSO USES GOOGLE ANALYTICS AND ADWORDS TO COMPILE INFORMATION COLLECTED VIA COOKIES IN A MANNER WHICH IS HELPFUL TO US IN ANALYZING VISITORS’ USE OF THE SITE. GOOGLE ANALYTICS ALSO USES THIS INFORMATION TO PLACE ADVERTISEMENTS FOR OUR PRODUCTS ON OTHER SITES THAT YOU VISIT AFTER YOU VISIT OUR WEBSITE. THESE ADVERTISEMENTS MAY BE BASED ON THE PAGES YOU VISITED DURING YOUR USE OF OUR WEBSITE. THIS INFORMATION MAY BE SHARED WITH OTHER ORGANIZATIONS SUCH AS ADVERTISERS AND OUR PARTNERS, WHO MIGHT USE IT WITH INFORMATION ABOUT HOW YOU USE OTHER WEBSITES, INCLUDING TO IDENTIFY SHARED INTERESTS AND BEHAVIORS ACROSS GROUPS OF USERS WHO VISIT OUR (AND OTHER) WEBSITE. TO LEARN MORE, VISIT “HOW GOOGLE USES DATA WHEN YOU USE OUR PARTNER SITES OR APPS.” USERS MAY OPT OUT OF GOOGLE’S USE OF COOKIES BY VISITING GOOGLE ANALYTICS OPT-OUT BROWSER ADD-ON. USERS MAY OPT OUT OF THIRD PARTY VENDOR USE OF THE COOKIES BY VISITING THE NETWORK ADVERTISING INITIATIVE OPT-OUT PAGE.

WHAT INFORMATION DO WE SHARE AND WITH WHOM?

HELEN OF TROY DOES NOT RENT OR SELL CUSTOMER INFORMATION TO OUTSIDE MARKETERS. IN CERTAIN CIRCUMSTANCES, HELEN OF TROY MAY SHARE YOUR CUSTOMER INFORMATION WITH OUR SUBSIDIARIES OR AFFILIATES OR TRUSTED SERVICE PROVIDERS THAT NEED ACCESS TO YOUR INFORMATION TO PROVIDE OPERATIONAL OR OTHER SUPPORT SERVICES. TO ENSURE THE CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION, SERVICE PROVIDERS MUST AGREE TO SAFEGUARD YOUR INFORMATION IN STRICT COMPLIANCE WITH OUR POLICY. WE ALSO MAY PROVIDE INFORMATION TO REGULATORY AUTHORITIES AND LAW ENFORCEMENT OFFICIALS IN ACCORDANCE WITH APPLICABLE LAW OR WHEN WE OTHERWISE BELIEVE IN GOOD FAITH THAT THE LAW REQUIRES IT. IN THE EVENT OF A SALE OF ALL OR PART OF ONE OF OUR BUSINESSES, WE MAY SHARE CUSTOMER INFORMATION RELATED TO THAT BUSINESS AS PART OF THE TRANSACTION.

HELEN OF TROY MAY DISCLOSE AGGREGATED INFORMATION ABOUT OUR USERS, AND INFORMATION THAT DOES NOT IDENTIFY ANY INDIVIDUAL, WITHOUT RESTRICTION.

CAN I “OPT OUT” OF RECEIVING PROMOTIONAL E-MAILS FROM HELEN OF TROY?

HELEN OF TROY MAY SEND YOU E-MAILS WITH PROMOTIONAL OFFERS. IF YOU WOULD NO LONGER LIKE TO RECEIVE E-MAILED SPECIAL EVENT INFORMATION, SALES NOTIFICATIONS OR OTHER MESSAGES FROM HELEN OF TROY, YOU MAY CONTACT US AT 1-800-487-7273 OR [email protected] (MAILTO:[email protected]) AND YOUR E-MAIL ADDRESS WILL BE REMOVED FROM OUR MARKETING LIST OR CLICK HERE TO FILL AN OPT OUT REQUEST FORM

HOW CAN I ACCESS MY HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE?

YOU CAN ACCESS YOUR HELEN OF TROY INFORMATION OBTAINED THROUGH THIS WEBSITE BY CONTACTING US AT 1-800-487-7273 OR [email protected] OR CLICK HERE TO FILL AN INFORMATION REQUEST FORM.

ALL WEBSITE DESIGN, GRAPHICS, TEXT SELECTIONS ARRANGEMENT, AND SOFTWARE ARE COPYRIGHT 2017, HELEN OF TROY ALL RIGHTS RESERVED.