Sears, Roebuck and Co. Import Buying Policy and Procedures

It is the policy of Sears, Roebuck and Co. ("Sears"), when purchasing merchandise not produced in the United States, to contract only with reputable suppliers of mer chandise, the production facilities, business and labor practices, and merchandise of which comply with all applicable local and United States laws. Strict adherence is expected to local laws governing the working conditions, wages and minimum age of the workforce, and to all applicable United States laws and prohibitions.

Willful violation of this policy will result in the termination of the offending supplier.

In furtherance of this policy, Sears will:

1. Distribute a copy of this policy to all Sears domestic and overseas buying staff members and to all existing and prospective foreign suppliers,

2. Include contractual provisions reflecting this policy in all international buy ing agreements,

3. Instruct its foreign buying office personnel to visit periodically suppliers' facilities to monitor compliance with this policy, and

4. Report, under justifiable circumstances, violations by suppliers of foreign and/or United States law to appropriate law enforcement authorities.