California Transparency In Supply Chains Act Of 2010 Compliance

American Greetings Corporation, on its and its subsidiaries' behalves is committed to promoting and conducting business in an ethical and responsible manner. This includes supporting international principles aimed at protecting and promoting human rights, including its opposition to human trafficking and the exploitation of children.

Our commitment to respect human rights is reflected in our Suppliers' Code of Conduct, to which all of our suppliers are expected to honor. This Code of Conduct mandates that each supplier comply with all laws and regulations on bribery, corruption, and employment practices, including a prohibition on the use of child and forced labor.

To ensure our suppliers meet these standards, the Company conducts an internal review of its product supply chains. The Company also conducts internal and unannounced audits of its suppliers. The Company maintains accountability standards and has adopted corrective action procedures for suppliers that do not meet our standards, which may include termination of the supplier. In addition, the Company requires direct suppliers to certify that the materials incorporated into our products comply with all international laws, including those addressing human trafficking and slavery.

Additional efforts to ensure compliance with the Code of Conduct include the Company training certain employees and management on slavery and human trafficking and performing annual reviews of the Code of Conduct and audit procedures.