Tilly's
 

Conflict Minerals Disclosure

Conflict Minerals Disclosure

In July 2010, the United States Congress enacted legislation that requires certain public companies to provide disclosure about the use in products they manufacture (or contract to manufacture) of tin, tantalum, tungsten, gold or their derivatives ("Conflict Minerals") emanating from the Democratic Republic of the Congo and its adjoining countries (the "Covered Countries"). The legislation is codified in Section 13(p), and Rule 13p-1 (the "Rule"), under the Securities Exchange Act of 1934, as amended (the "Act"), and applies to issuers that manufacture or contract to manufacture products for which Conflict Minerals are necessary to the functionality or production.

As required by the Rule, Tillys, Inc. (the "Company") undertook an analysis of its products to determine whether it would be deemed under the Rule to manufacture or contract to manufacture any product in which any Conflict Mineral was necessary to the functionality or production of such product. As a result of that analysis, the Company determined that during the reporting period January 1, 2014 to December 31, 2014 (the "Relevant Period"), the Company contracted with certain vendors (the "Covered Vendors") to manufacture certain products (the "Covered Products") that contain Conflict Minerals necessary to the functionality or production of the Covered Products. Accordingly, the Company conducted a reasonable country of origin inquiry with respect to the Conflict Minerals in such Covered Products (the "RCOI"), as required by the Act.

The Company's RCOI process commenced with the preparation of a conflict minerals questionnaire based on the model questionnaires prepared by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative. The questionnaires were then distributed electronically to all Covered Vendors, as well as any other vendors that were used in the manufacture of the Company's products or were contracted to manufacture products for the Company during the Covered Period (collectively, the "Vendors"). The Vendors completed such questionnaires and electronically returned them to the Company. Buying and legal personnel at the Company then reviewed the responses. When the nature of a response warranted further analysis, Company personnel contacted the relevant Vendor for further evidence, either oral or written, to clarify or validate the response.

Based on the results of its RCOI, the Company determined it has no reason to believe that, during the Relevant Period, its Covered Products contain Conflict Minerals that may have originated in the Covered Countries. The foregoing information is separately disclosed on the Company's website at www.tillys.com, on the Investor Relations page, under the heading "Conflict Minerals Disclosure."