Cabela's, Inc.

The Cabela's Business Code of Conduct and Ethics reflects our overall standards for proper behavior and corporate values, and is signed by every employee. Cabela's also has a specific Code of Conduct that must be signed by all business partners and vendors committing them to doing business in an ethical manner and consistent with respect for labor standards. This code of conduct includes a specific certification that there is no use of forced labor of any type, which would include slavery and human trafficking, by the business partner or supplier, and requires that the business partner or supplier maintain on file documentation to prove compliance with the Cabela's code of conduct and to make such documentation available to Cabela's or its designated auditors. Cabela's uses both internal and external auditors to evaluate compliance with the code of conduct obligations. Cabela's requires that all business partners and vendors identify the source of the country from which they are providing products to Cabela's. Cabela's has in place accountability standards and procedures for any employee or business partner or vendor who would fail to meet the obligations to abide by the basic principle to not use forced labor of any kind, including human trafficking and slavery, in the Cabela's supply chain. Cabela's employees with responsibility for supply chain management receive training on the Cabela's Code of Conduct and Ethics and the Code of Conduct signed by all business partners and vendors.