Burlington’s Commitment to Product Safety and Chemical Management

As part of our commitment to safety, Burlington Stores, Inc. (“Burlington”) continues to execute strategies that support our goal of chemical management. With chemical regulations quickly emerging, Burlington is seeking opportunities to create harmonized chemical management policies that are informed by US Federal, State and regional regulations, as well as hazard and risk-based considerations.

Product Chemical Management Overview

Burlington has launched a Center of Excellence for Product Safety & Regulatory Compliance to provide oversight to Burlington’s product safety and chemical management program. We also partnered with a third-party consultant to conduct a thorough review of our chemical management processes and procedures, as well as peer benchmarking. Through the course of that work, which considered the complexities of the off-price business model, we’ve established the following roadmap:

1. Industry partnerships: Explore partnerships with industry groups to leverage a consistent set of tools and processes to support best practices, monitor vendor performance, and encourage use of safer chemicals.
2. Industry certifications: Provide recommendations to internal and external business partners for third-party certifications that demonstrate safer chemicals management for certain categories.
3. Internal engagement: Identify vendors that have reduced and/ or eliminated chemicals of concern in their supply chain to influence purchasing decisions.
4. Supply chain engagement: Continue to communicate chemical compliance expectations to our vendors through our manuals and protocols. Encourage vendors to establish their own chemical compliance programs that demonstrate a beyond legal compliance approach.
5. Compliance and monitoring: Through third-party testing of products, product components, and supply chain auditing using internal and industry data platforms, we will monitor the performance of our vendors and verify compliance with US chemical regulations and Burlington’s own chemical restrictions.

Product Chemical Management Program

At Burlington, we believe that reducing and eliminating harmful chemicals is everyone’s responsibility. While our Chemical Compliance policies apply to all products offered to Burlington, our Chemical Management Program outlines initial categories of products and packaging, where we expect certain chemicals of concern to be reduced or eliminated. Burlington’s Chemical Management Program will be implemented in a multi-phase approach. During this time, we will continue to monitor the efficacy of our program and adjust process and procedures as needed.

With the roadmap as our guide, Burlington will continue to work with our suppliers and vendors to identify additional opportunities going forward.

Oversight

Burlington’s Chemical Management Program is led by their Center of Excellence for Product Safety & Regulatory Compliance with support from Legal, Environmental Sustainability, and Merchandising Departments.

Program Scope (Initial phase)

Chemical Compliance Documents and Restricted Substance List (RSL)
Issue an integrated Product Safety & Chemical Compliance manual that includes an updated RSL.

Third party certifications and preferred materials
Compile and distribute list of third-party certifications and preferred materials for specific product categories

Burlington’s Long-Term Product Chemical Management Strategy

As an off-price retailer, Burlington’s opportunistic buying model allows us to offer branded product at a great value to our customers. Although Burlington does not develop and manufacture the products we buy, we only work with suppliers that uphold our ethical and safety standards. To that end, we will continue to make incremental enhancements to our chemical management program that support our off-price business model.

Product Safety Compliance Program

As part of Burlington’s Product Safety Compliance Program, all new vendors who supply products to Burlington are required to complete and sign the Company’s Vendor Agreement as part of the new vendor on-boarding package. Existing vendors agree to the Company’s Purchase Order Terms and Conditions with each purchase made. By signing the Vendor Agreement form and/or accepting and fulfilling any order, vendors represent and warrant that they will comply with such Terms and Conditions, as well as various vendor facing documents, including the Burlington Vendor Manual; Burlington Code of Conduct, Product Safety and Social Compliance Manual; and Burlington Chemical Compliance Manual. All products supplied to Burlington are required to comply with all applicable laws, rules and regulations in the US, as well as the country of manufacture.

Burlington strictly enforces the rigorous requirements for products subject to a Consumer Product Safety Commission (CPSC) rule, ban or standard. Where Burlington is the importer of record, vendors are required to submit GCCs and CPCs as well as corresponding test reports prior to shipping.

Burlington maintains a comprehensive food safety program and works closely with our supply chain to ensure compliance with US Food & Drug Administration (FDA) food safety regulations, including the Food Safety Modernization Act (FSMA). Burlington also takes steps to ensure the cosmetic products we sell are safe for use. Vendors are required to certify that their cosmetic products are compliant with the most current US FDA laws and regulations, as well as any US state regulations.

Burlington takes a strategic approach for purchasing and selling products that meet or exceed legal standards for safety. We employ heightened safety measures for product categories that present the greatest safety risk to our customers. Any product that fails to comply with applicable consumer product safety regulations or creates an unreasonable risk of serious injury will be subject to our product recall process.

Hazardous Waste Program

Burlington is committed to the safe and responsible management of hazardous waste products in our stores and distribution centers. Hazardous waste includes materials and substances which pose a hazard to the environment when improperly disposed. Burlington has a comprehensive hazardous waste program to ensure the proper disposal of these products.

Our store and distribution center associates nationwide are trained to separate and properly store hazardous and regulated materials. These materials are then collected by a third party specializing in proper disposal of these materials.

Operational Chemical Management

Over the last two years, we made progress in reducing our operational chemical footprint in our stores and DCs by assessing and making changes in priority operational supplies including:

• Phasing out receipt papers with phenol-based coatings (e.g., BPA, BPS, BPF, BPB, BPAF) in stores nationwide to eliminate chemicals on tape handled by store Associates and customers.
• Launching a green cleaning program utilizing certified eco-friendly cleaning products, in stores, that are third-party certified under the UL ECOLOGO® program. The products are formulated to eliminate exposure to harsher chemical ingredients by contract cleaners, Associates, and customers visiting our stores. They are not only safer for people, but they are also safer for the environment. Certified eco-friendly cleaning products were approved and rolled out to all stores by the end of 2022.
• Eliminated single-use plastics from our cafeterias in our NJ corporate locations. Through a partnership with the Corporate Services team and our food services provider, the Sustainability team worked to procure eco-friendly alternatives to the previously used polystyrene and plastic carryout containers as well as single use plastic utensils, straws, plates, cups, and more.

We continue to identify opportunities to address the management of our chemical footprint across our operations. We plan to provide updates on our efforts in our annual CSR Report.