Cracker Barrel Old Country Store, Inc.California Transparency in Supply Chains Act

Human Trafficking

Cracker Barrel is committed to conducting business in an honest and ethical manner and holds its suppliers and vendors to rigorous standards. In accordance with the California Transparency in Supply Chains Act (SB 657), Cracker Barrel’s efforts to address human trafficking and slavery in its supply chain are described below. Cracker Barrel remains committed to participating in further conversations with its suppliers, non-governmental organizations and regulators about continued enhancements to these efforts.

Verification

Ensuring a positive working environment that promotes safety and fosters a healthy work place is central to who we are and what we do at Cracker Barrel, and we apply this principle across our full supply chain. To this end, we have processes and procedures in place to evaluate our vendors and their factories, starting from the moment a partnership is established. As part of our set-up process with any new vendor, we inspect their business and factories and evaluate the general conditions of the countries where Cracker Barrel’s products are produced.

Additionally, we request that our vendors/agents share their Social Compliance audit documentation with us each month. This documentation is reviewed quarterly by our Retail/CTPAT core team, which provides recommendations for corrective action, as needed. Currently these verification efforts are carried out by our own personnel and not through a third party.

Audits

Each quarter, we also randomly perform a social compliance and audit of vendors.

Our retail management team also meets on a quarterly basis and conducts risk assessments across Cracker Barrel’s supply chain. These meetings will include human trafficking and slavery risk assessments. In addition, certain team members regularly tour new and existing factories and, as a matter of routine, check for social compliance by the factories.

We are currently developing a social compliance program that will feature announced and unannounced independent audits conducted by third-party agents, which will verify whether vendors and their factories are complying with our standards. As part of this program, audits will be conducted on a quarterly random basis or targeted if an issue is reasonably suspected. The audits may or may not be unannounced.

If a vendor/factory fails an audit or inspection and fails to meet any corrective action, we will cease doing business with the vendor/factory.

Certification

Our retail documents require our vendors/agents to comply with all applicable laws and regulations. Vendors are required to execute certain retail documents to acknowledge their agreement to comply with all of our business terms and requirements. We are in the process of revising our retail documents to include specific provisions regarding slavery and human trafficking. In the event a vendor/agent fails to comply with our business terms and requirements, we will cease doing business with the vendor/agent.

Internal Accountability

We strictly enforce our Code of Business Conduct and Ethics, which requires employees to comply with all laws, including labor laws, applicable to the company and its operations. Employee compliance certification is required annually, and any violation of the Code of Conduct may lead to disciplinary action. We are in the process of revising our Code of Conduct to include specific provisions regarding slavery and human trafficking.

Training

As part of our commitment to prioritizing these critical issues, we are currently creating a mandatory training program on social compliance for any employees who are responsible for sourcing and merchandising decisions and/or supply chain management.