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|CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURE STATEMENT
The Cabela's Business Code of Conduct and Ethics reflects our overall standards for proper behavior and corporate values, and is signed by every employee. Cabela's also has a specific Code of Conduct that must be signed by all business partners and vendors committing them to doing business in an ethical manner and consistent with respect for labor standards. This code of conduct includes a specific certification that there is no use of forced labor of any type, which would include slavery and human trafficking, by the business partner or supplier, and requires that the business partner or supplier maintain on file documentation to prove compliance with the Cabela's code of conduct and to make such documentation available to Cabela's or its designated auditors. Cabela's uses both internal and external auditors to evaluate compliance with the code of conduct obligations. Cabela's requires that all business partners and vendors identify the source of the country from which they are providing products to Cabela's. Cabela's has in place accountability standards and procedures for any employee or business partner or vendor who would fail to meet the obligations to abide by the basic principle to not use forced labor of any kind, including human trafficking and slavery, in the Cabela's supply chain. Cabela's employees with responsibility for supply chain management receive training on the Cabela's Code of Conduct and Ethics and the Code of Conduct signed by all business partners and vendors.
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Section 1502) intends to prevent the use of certain "Conflict Minerals" that support conflict in the Democratic Republic of Congo (DRC) or adjoining countries. "Conflict Minerals" include: columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives, and could be expanded in the future to include other minerals or their derivatives. It is important to note that all previously mentioned ores/metals are included in the US government’s definition of Conflict Minerals, not merely those ores/metals which have been identified to fund or support conflict in the DRC or adjoining countries. As a result, Cabela’s has also chosen to differentiate between all Conflict Minerals, and those Conflict Minerals that have been identified to fund or support conflict in the DRC or adjoining countries.
Cabela's will seek to avoid the use of Conflict Minerals which support conflict in the DRC or adjoining countries and will comply with the reporting obligations required under Section 1502, as well as related rules and regulations issued by the U.S. Securities and Exchange Commission, including the requirement that Cabela’s conduct inquiries into the source of any Conflict Minerals included in its products.
Cabela's has adopted a due diligence reporting process and will strive to obtain conflict-free declarations from suppliers to ensure transparency and corporate social responsibility throughout the supply chain.
Cabela's suppliers are required to acknowledge Cabela’s Vendor Code of Conduct, which includes requirements regarding Conflict Minerals and responsible sourcing. Suppliers are also responsible for passing the same requirements on to their suppliers.
Suppliers are required to declare that all products supplied either:
1. do not contain tantalum, tin, tungsten or gold necessary to production or functionality; or,
2. if they do contain these minerals, they originate from non-conflict areas or from smelters that have been validated by an independent private sector party to be conflict free.
Cabela's will continue to evaluate its relationships with suppliers on a continuous basis to ensure compliance with this policy, and reserves the right to request additional documentation from its suppliers regarding the source of any Conflict Minerals included in its products. In addition, suppliers must maintain and provide to Cabela’s upon request traceability data for a minimum of five years. Suppliers who do not comply with these requirements shall be reviewed by Cabela's supply chain organization for future business.
Thorough and credible Conflict Mineral traceability information was available on an extremely limited basis during 2012; this is expected to improve marginally in 2013. These information limitations are not unique to Cabela's, but reflect the status of Conflict Minerals traceability systems and documentation capabilities throughout the globe. We are monitoring developments of credible and authoritative traceability systems/ data as they become available and will review Conflict Mineral declarations from our suppliers at least annually.
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