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•	to identify any products the Company sells or offers for sale to its customers that, for purposes of Rule 13p-1 and Item 1.01, it manufactures or contracts to manufacture that contain one or more Conflict Minerals that are necessary to the functionality or production of such products ("CM Products");

•

to make good faith, reasonable country of origin inquiries ("RCOIs") to determine the country of origin of each Conflict Mineral contained in one or more of the CM Products the Company sells and that is necessary to the functionality or production of such CM Product (each, a "Necessary Conflict Mineral") or that such Necessary Conflict Mineral came from recycled or scrap sources (as defined in Item 1.01 and referred to herein as "Recycled or Scrap Sources"); and

•	where required, to conduct due diligence on the source and chain of custody of Necessary Conflict Minerals contained in CM Products.

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the Company sold and offered for sale to its customers the Eyeglass Lenses that: (1) the Company manufactured during the Reporting Year; and (2) contained the Conflict Mineral tantalum that may be deemed to be necessary to the functionality or production of the Eyeglass Lenses (the "Necessary Tantalum"). The Necessary Tantalum was contained in the Materials, which the Company acquired from the Eyeglass Materials Supplier; and

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the Company sold and offered for sale to its customers a number of items of Jewelry purchased from the Jewelry Suppliers that: (a) under the provisions of Rule 13p-1 and Item 1.01, the Company may be deemed to have contracted to manufacture, and the manufacture of which was completed in the Reporting Year; and (b) contained the Conflict Mineral gold that may be deemed to be necessary to the functionality or production of the Jewelry for purposes of Rule 13p-1 and Item 1.01 (the "Necessary Gold").

(a)	the Company notified the Suppliers of the Conflict Minerals Policy, the Company’s expectations regarding its compliance obligations under Rule 13p-1 and its expectations for the Suppliers’ cooperation in the Company’s compliance activities;

(b)	provided the Suppliers with access to the Retail Industry Leaders Association’s Conflict Minerals awareness training;

(c)

delivered live or recorded training to the Suppliers on the Company’s Compliance Portal regarding the use of the Company’s Conflict Minerals survey tool, which is based on the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template and is designed to elicit representations and certifications from the Suppliers to provide the Company with reasonable assurance as to country of origin and source of, in the case of the Products, the Necessary Tantalum and Necessary Gold (the "Conflict Minerals Survey");

(d)	required and assessed appropriate completion of the Conflict Minerals Survey by each Supplier;

(e)	obtained from each Supplier, and analyzed and took steps to confirm each Supplier’s responses to, the Conflict Minerals Survey;

(f)	escalated inquiries and communications with any Supplier not providing complete and acceptable responses and confirmed that follow-up training regarding Rule 13p-1, Item 1.01, the Conflict Minerals Survey and the Compliance Portal was conducted as the Company deemed appropriate based on its assessment of that Supplier’s completion of the Conflict Minerals Survey;

(g)	obtained final completion of each Supplier’s Conflict Minerals Survey;

(h)	analyzed and took steps to confirm any follow-up responses of any Supplier required to be made to the Conflict Minerals Survey or other inquiries made of any Supplier; and

(i)

compiled the results of the Conflict Minerals Surveys and other inquiries and reviewed such results to determine the country of origin of the Necessary Tantalum and the Necessary Gold, whether the Necessary Tantalum and the Necessary Gold came from, or the Company could reasonably believe it came from, Recycled or Scrap Sources or whether the Company had any reason to believe that any of the Necessary Tantalum or Necessary Gold may have come from a Covered Country and did not come from a Recycled or Scrap Source.

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