CA Transparency in Supply Chains Act

DISCLOSURE STATEMENT

Hard Rock Cafe International (USA), Inc. and its affiliated companies ("Hard Rock") support the goals of the California Transparency in Supply Chains Act of 2010 and strive to lead by example through our observation of good human rights and labor practices throughout our business activities. Hard Rock has built its business over the last forty years on the conviction that to have long-term success, we do not only have to comply with all applicable legal requirements and ensure that all our activities are sustainable, but additionally we have to create significant value for society.

Hard Rock's own business activities comply with the laws and regulations regarding slavery and human trafficking in the countries in which it does business and requires that its authorized vendors and their third party manufacturers, if any, who supply our products certify that they comply with such laws as well. Specifically, Hard Rock has a vendor compliance guide in place with its authorized vendors requiring them to confirm to Hard Rock their compliance with the local laws and regulations regarding slavery and human trafficking of the country or countries in which they are doing business before they may produce , manufacture or sell products to Hard Rock for Hard Rock to then offer for sale to its guests.

Hard Rock is dedicated to our ethical expectations in a lawful and manner and it is our expectation, and requirement, thats conduct themselves in such a manner as well.

1. Merchandise Supply Chains / Vendors

Through Hard Rock's Vendor Compliance Guide, we commit to foster responsible in practices our merchandise supply chain. Hard Rock's Ethical Code of Conduct for Vendors, which must be accepted and adhered to by our vendors, establishes non-negotiable minimum standards for Hard Rock's authorized vendors and third party manufacturers in the areas of health, safety, labor and employment.

2. Vendor Audits

Hard Rock reserves the right to verify our vendors' compliance with Hard Rock's Code. Hard Rock confirms initial and ongoing compliance through either a combination of vendor representations, Hard Rock inspections, or inspections performed by an authorized Hard Rock vendor of its third party manufacturers.

In the event that Hard Rock becomes aware of any actions or conditions not in compliance with Hard Rock's Code, Hard Rock reserves the right to demand corrective measures. Additionally, Hard Rock reserves the right to terminate an agreement with any vendor or third party manufacturer who does not comply with Hard Rock's Code.

3. Human Rights in our business activities

Hard Rock fully supports the United Nations Global Compact's (UNGC) guiding principles on human rights and labor, and aims to provide an example of good human rights' and labor practices throughout our business activities.

4. Code of Business Conduct

Since Hard Rock was founded, Hard Rock has been operating on a foundation governed by integrity, honesty, fair dealing and full compliance with all applicable laws. Hard Rock employees worldwide have upheld and lived this commitment in their every day responsibilities, and Hard Rock's reputation amongst its employees and the business community remains one of its most important assets today.

Hard Rock's Code of Conduct and Code of Ethics prescribe certain values and principles which Hard Rock has committed to worldwide. These Codes encourage the continued implementation of the bedrock of Hard Rock's business philosophy by establishing certain nonnegotiable minimum standards of behavior in key areas.

5. Employee Training

Hard Rock's Employee Handbook is accessible to all employees via an intranet site.The Employee Handbook is updated annually and the release of such updates is communicated to all employees.Hard Rock provides its employees with elearning training opportunities and in person training sessions on the various components of Hard Rock's business principles and includes discussions on social issues including child labor, human trafficking and slavery to increase awareness on such labor-related and human rights issues.