At e.l.f. Beauty, we are committed to conducting business in a legal, ethical, and responsible manner and recognize the importance of safe working conditions around the world.

This Canadian Fighting Against Forced Labor and Child Labor in Supply Chains Act 2023 statement is made in accordance with section 11(1) of the Canadian Fighting Against Forced Labor and Child Labor in Supply Chains Act 2023 and outlines the actions undertaken in the fiscal year listed above to prevent and reduce the risk that forced labor or child labor is used in our business and enterprise.

In this Canadian Fighting Against Forced Labor and Child Labor in Supply Chains Act 2023 statement, reference to “we” and “us” generally refer to the entire e.l.f. Beauty group unless expressly provided otherwise.¹

We provide a safe and healthy workplace and comply with applicable health and safety laws, regulations and international requirements. We support human and workplace rights as articulated in the United Nations’ Universal Declaration of Human Rights which recognizes that “all human beings are born free and equal in dignity and rights”. Consequently, we take a proactive approach to respecting fundamental human rights and embed this understanding throughout our operations and supply chain.

We expressly prohibit modern slavery of any kind in our operations and supply chain. We prohibit the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, slave labor and any form of human trafficking within our company and by any company that directly supplies or provides services to our business. We prioritize activities and business partners that demonstrate a commitment to respecting fundamental human rights, providing safe and conducive working conditions, and advancing responsible business operations.

In this Fighting Against Forced Labor and Child Labor in Supply Chains Act statement, reference to “we” and “us” generally refer to the entire e.l.f. Beauty group unless expressly provided otherwise.

e.l.f. Beauty, Inc. (NYSE: ELF) is fueled by a belief that anything is e.l.f.ing possible. We are a different kind of company that disrupts norms, shapes culture and connects communities, committed to positivity, inclusivity and accessibility.

Our mission is clear: to make the best of beauty accessible to every eye, lip, face and skin concern. e.l.f. Beauty and its brands, e.l.f. Cosmetics, e.l.f. SKIN, Well People, Naturium and rhode, are led by purpose, driven by results and elevated by superpowers, offering e.l.f. clean and vegan products. e.l.f. Beauty proudly stands as the first beauty company with Fair Trade Certified™ facilities. With a kind heart at the center of e.l.f.’s ethos, the company donates at least 2% of the prior year’s profits to organizations that make positive impacts.

e.l.f. Cosmetics, Inc. is the primary operating subsidiary of the e.l.f. Beauty group. e.l.f. Cosmetics, Inc. is headquartered in Oakland, California. W3LL People, Inc. and Naturium LLC, each a wholly owned subsidiary of e.l.f. Cosmetics, Inc., own the Well People and Naturium brands, respectively.

We strive to provide products that deliver extraordinary value and efficacy and are safe for consumers. We are driven to “do the right thing” in our business, which includes, among other things, prioritizing suppliers that demonstrate a strong commitment to protecting fundamental human rights, foster safe and conducive workplaces, treat their employees fairly and advance responsible business practices. To achieve this end, we collaborate with our suppliers and key stakeholders to commit ourselves to corporate responsibility through our operations and procurement activities.

Our products are manufactured by third-party suppliers that are diversified globally primarily in Asia, Europe and North America. We prioritize ethical sourcing practices and ensure that our suppliers uphold our principles and values when providing products and services to our Company. We require our suppliers to agree in writing to, and adhere to, our Supplier Code of Conduct (which is discussed below). Our Supplier Code of Conduct addresses working conditions for suppliers and specifically prohibits, among other things, the use of involuntary or forced labor, human trafficking, child labor, human rights violations, animal testing, and harassment and abuse.

Our supply chains are relatively complex due to the multi-tiered nature of our sourcing process. While we primarily work with suppliers who deliver finished products, our suppliers rely on subcontractors to perform key production activities. Despite the complexity and multi-tiered nature of our supply chain, we are committed to ensuring ethical practices throughout our supply chain by engaging with our suppliers to ensure that subcontractors are held to the same standards established by our Supplier Code of Conduct.

We depend on our suppliers and their sub-suppliers for most of the value added throughout our supply chain. Our leadership team oversees our supplier relationships and regularly reviews our supplier base. In cases where suppliers operate in high-risk regions, we exercise heightened diligence to help prevent modern slavery and human rights violations. We hold our suppliers accountable, ensuring they source responsibly, even when decisions fall outside the scope of our purchases. When risks are identified within our supply chain, we collaborate with our suppliers to address these concerns by implementing corrective action plans, with clearly defined timelines for improvement.

We may, where appropriate, conduct onsite audits of certain suppliers. Selection may be based on a range of factors, including geography, type of material, and potential impact to the business.

If our audit shows that a supplier is in violation of our Supplier Code of Conduct or if we suspect a supplier is in violation of any requirement of our Supplier Code of Conduct or our manufacturing or quality agreements, we will conduct an inquiry. If a potential violation is identified, we will address the issue with the supplier and set expectations for how the situation is to be addressed. If a non-compliance issue is not resolved in a timely manner, then we re-evaluate our business relationship, and assess appropriate next steps, with that supplier, which may include termination of the business relationship.

Our Code of Business Conduct and Ethics is the foundation of our approach to ethical conduct. Our Company’s Code of Business Conduct and Ethics sets our expectations for our employees, partners and suppliers on a variety of ethical issues. Our employees are expected to be familiar with our Code of Business Conduct and Ethics and to act with honesty and integrity, including appropriately managing actual or potential conflicts of interest. Our employees are also expected to comply with all applicable laws, rules, and regulations and to take personal responsibility for meeting these standards.

Our Supplier Code of Conduct specifies the minimum code of conduct that we require our suppliers and their sub-suppliers to respect and follow when they engage in transactions with and on behalf of us. The standards are designed to protect the rights of workers in the supply chain and ensure compliance with laws.

Our Supplier Code of Conduct among other issues, promotes respect for human rights, freedom of association and collective bargaining, the rights of indigenous people, fair treatment of migrant workers and safe and healthy working environments, prohibits discrimination, abuse and harassment, forced labor and human trafficking, and child labor, and requires our suppliers to comply with labor-related laws and regulations.

Our Supplier Code of Conduct requires our suppliers to establish whistleblowing mechanisms and accept complaints from employees. It also establishes the importance of whistleblower protection and protection from retaliation.