7-Eleven takes various steps to evaluate and address risks of Forced Labor in our supply chain.

For example:

Clear Day-One Expectation-Setting

From the outset (and through the relationship) we make clear to our direct suppliers (“Suppliers”) that they are expected to share our “commitment to high standards of ethical business conduct.” In accordance with those expectations, as noted above, Suppliers must certify compliance with our Supplier 7-Eleven California Transparency in Supply Chains Act (“CTSCA”) Policy.

Unannounced Audits

Our Supplier 7-Eleven CTSCA Policy provides, among other things, that Suppliers must “agree to allow 7-Eleven (or third parties acting on their behalf) to conduct unrestricted audits of Supplier and its facilities, without advance notice, to verify compliance with this Anti-Forced Labor Policy.”

Compliance Advisor

In support of our verification process, 7-Eleven’s Corporate Compliance Department serve as our advisor (“Compliance Department”). The Compliance Department is assisting in our ongoing effort to develop formalized Anti-Forced Labor Policy Protocols. The Compliance Department, assists on an as-needed basis on compliance-related issues related to identifying, assessing, and managing the risk of Forced Labor in our supply chains.

Immediate Notification Requirement

Both 7-Eleven’s CTSCA Policy and its Standard Contract Language provide that Suppliers have a duty to “immediately” notify the Company when they have “reason to believe” they are in violation of the Company’s expectations concerning Forced Labor.

“Auditing” refers to activities a company takes to evaluate ongoing supplier compliance with existing company standards for human trafficking and slavery in its supply chain(s).

Audit Rights

Our Supplier CTSCA Policy informs all Suppliers that they “must agree to allow 7-Eleven (or third parties acting on their behalf) to conduct unrestricted audits of Supplier and its facilities, without advance notice, to verify compliance with this Anti-Forced Labor Policy.”

Targeted Refresher Communications

7-Eleven may periodically send Suppliers targeted communications reminding them of their obligation to (i) immediately notify us if and when they have reason to believe they are in violation of our clearly articulated requirements and expectations, and (ii) comply with our Supplier CTSCA Policy.

Access to Records

Our Supplier CTSCA Policy requires Suppliers to “maintain records to verify compliance with this Policy and all applicable laws” and to “provide all such records during an audit.”

7-Eleven’s Supplier CTSCA Policy requires Suppliers “to verify their compliance with the obligations set forth in the Policy, including that the products they provide to 7-Eleven comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.” We are in the process of developing our program.

7-Eleven maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding Forced Labor.

Clear Expectations

The internal 7-Eleven Code of Conduct (the “Code”) outlines 7-Eleven’s commitment to “ethical conduct and compliance with applicable law.” Our internal accountability standards and expectations for employees, officers and directors, which are monitored by [7-Eleven Compliance Department], are set forth in the Code, which also encourages employees to seek advice about ethics- or compliance-related questions and to report misconduct. 7-Eleven has a policy against retaliation, and employees are informed that 7-Eleven “does not tolerate retaliation against anyone for raising concerns or reporting possible misconduct in good faith or for assisting in the investigation of possible misconduct.”

Preventative and Corrective Action

We encourage any employee, officer or director subject to the 7-Eleven Code of Conduct to seek guidance if they have any questions or concerns. The 7-Eleven Code of Conduct requires that employees “[p]romptly report concerns about actions that may be inconsistent with the Code, policies and procedures or applicable law.” Such reports are fully and promptly investigated, and employees are expected to “fully cooperate with any investigations and audits, including compliance audits and any Company investigation into suspected violations of the Code.” Non-compliance with 7-Eleven’s Code of Conduct, policies and procedures, or applicable law can result in corrective action up to and including termination. We may also exercise our right to notify the appropriate authorities of potential violations of applicable laws, rules or regulations.

Hotline Reporting

We maintain a confidential ethics hotline 24-hours a day, accessible via phone or text. In addition, questions or concerns can also be sent via email or website. The hotline and other contact information is generally available to anyone who wishes to report ethics or compliance related matters or obtain compliance or ethics related advice.

CTSCA Training is currently available.

This Disclosure outlines our efforts to ensure that our suppliers meet the requirements of the CTSCA. We are committed to conducting business ethically and we strive to work with suppliers that share these values and commitments. 7-Eleven will continue to monitor and assess our supply chains and will collaborate with our Compliance Department to enhance those efforts.