Overview of Business
−Removed: The Honest Company (the “Company,” which may also be referred to as “we,” “us” or “our”) is a personal care company dedicated to creating cleanly-formulated and sustainably-designed products .
+Added: Founded in 2012, The Honest Company (the “Company,” or “Honest,” or which may also be referred to as “we,” “us” or “our”) is a personal care company dedicated to creating cleanly-formulated and sustainably-designed products for everyone from babies to adults.
+Added: By combining thoughtful design with science-based innovation, we deliver personal care products for everyone from babies to adults, spanning categories across wipes, personal care, diapers, and beauty.
Our commitment to our core values, continual innovation and engaging our community has differentiated and elevated our brand and our products.
−Removed: Since our launch in 2012, we have been dedicated to developing clean, sustainable, effective and thoughtfully designed products.
−Removed: By doing so with transparency, we have cultivated deep trust around what matters most to our consumers:
+Added: Since our launch, we have cultivated deep trust around what matters most to our consumers:
their health, their families and their homes.
We seek to meet consumers wherever they want to shop, balancing deep consumer connection with broad convenience and availability.
−Removed: Our distribution strategy positions us for continued growth through our trusted brand and award-winning multi-category product offering.
+Added: We believe our distribution strategy positions us for continued growth through our trusted brand and award-winning multi-category product offering.
Our Products and Product Categories
Our Chief Executive Officer, as the chief operating decision maker, organizes the Company, manages resource allocations, and measures performance on the basis of one operating segment.
−Removed: We offer an array of personal care products, including diapers, wipes and adult facial care (including skin and color cosmetics).
+Added: We offer an array of cleanly-formulated and sustainably-designed products, including a portfolio of wipes and a personal care collection for everyone from babies to adults, as well as diapers.
We use cleanly-formulated and safe ingredients designed for the whole family, including many naturally-derived ingredients that, most importantly, are effective.
+Added: We also offer a portfolio of wipes, including all-purpose wipes, flushable wipes in both toddler and adult variations, sanitizing wipes, and make-up remover wipes.
+Added: Our Clean Conscious® wipes are compostable and plant-based, made with over 99% water and designed to protect delicate skin.
+Added: We have an extensive collection of personal care products for everyone from babies to adults, as well as adult facial care products designed for a range of skin types and concerns, many of which are certified by trusted experts and institutions, including the National Eczema Association.
+Added: Our ingredients and formulas are toxicologist-audited for potential health concerns.
Primary components of our diapers include responsibly sourced, plant-based fluff pulp and other plant-derived materials.
Our diapers have an extensive modern and efficient design that uses less material.
−Removed: Our Clean Conscious TM wipes are compostable and plant-based, made with over 99% water and gentle on sensitive skin.
−Removed: We have an extensive line of bath and body care products for babies, as well as adult facial care products designed for a range of skin types and concerns, many of which are certified by trusted experts and institutions, including the National Eczema Association.
−Removed: Our ingredients and formulas are toxicologist-audited for potential health concerns.
−Removed: We also offer baby clothing made with organic cotton, family flushable wipes, sanitizing wipes and hand sanitizer made with plant-based ingredients.
−Removed: Our Integrated Omnichannel Presence
−Removed: Our omnichannel presence seeks to meet consumers wherever they want to shop, balancing deep consumer connection with broad convenience and availability.
−Removed: Since our launch, we have built a well-integrated omnichannel presence by expanding our product availability, including the launch of strategic partnerships with Target, Amazon and Walmart in 2014, 2017 and 2022, respectively , as well as distribution with many other retailers nationwide .
−Removed: We also increase availability of our products to more consumers through our leading retailers and their websites and Honest.com.
−Removed: Our strategic retail partnerships with leading omnichannel retailers sell our products through brick and mortar stores and on their own websites.
+Added: Our Distribution Strategy
+Added: We seek to meet consumers wherever they want to shop, balancing deep consumer connection with broad convenience and availability.
+Added: Our distribution strategy positions us for continued growth through our trusted brand and award-winning multi-category product offerings.
+Added: Since our launch, we have expanded our product availability, including the launch of strategic partnerships with Target, Amazon and Walmart in 2014, 2017 and 2022, respectively , as well as distribution with many other retailers nationwide .
+Added: We have retail partnerships with leading retailers that sell our products through brick and mortar stores and on their own websites.
Our retail partnerships expand brand awareness and product availability , creating meaningful marketing efficiencies as we continue to scale.
−Removed: Additionally, these partnerships support our differentiated value proposition by making our products conveniently available in the many places where our consumer shops.
−Removed: We maintain direct relationships with our consumers via our flagship digital platform, Honest.com, which allows us to influence brand experience and better understand consumer preferences and behavior.
−Removed: Our website showcases the entirety of our product portfolio, excluding baby apparel, offers exclusive products and services including our subscription service, houses branded content featured on product detail pages and our blog, and facilitates new product feedback.
−Removed: In addition to shopping for our products a la carte, consumers have the option to subscribe to our popular diapers and wipes bundle subscription.
−Removed: All-commodity volume ( “ACV” ) is the measurement of a product’s distribution weighted by the overall dollar retail sales attributable to the retail location distributing such product;
−Removed: a retail location would be counted as having sold the product or product group if at least one unit of the product was scanned for sale within the relevant time period.
−Removed: This metric provides a measurement of retail penetration that takes into account the importance of selling through retail locations with higher overall retail sales volumes, and as a result we believe that our competitors generally use the same measurement.
−Removed: For the 13-weeks ended January 5, 2025, in total we had approximately 83 points ACV in national multi-outlet stores, as compared with 84 points for the 13-weeks ended January 7, 2024, primarily driven by product and store mix changes at our key retailers.
−Removed: Below is our ACV weighted distribution for the 13-week period ended:
+Added: Additionally, these retail partnerships support our differentiated value proposition by making our products conveniently available in the many places where our consumer shops.
+Added: Effective December 31, 2025, we have transitioned away from Honest.com as a shipping and fulfillment channel, while maintaining Honest.com as a resource for educating consumers, showcasing our complete product portfolio, and driving consumers to purchase through our leading retailers and their websites, and third-party ecommerce sites.
Our Growth Strategy
−Removed: The core of our growth strategy centers around increasing physical availability of our products through expanded stores, doors, aisles, shelves and facings.
+Added: The core of our growth strategy centers around increasing physical and digital availability of our products, including through expanded stores, doors, aisles, shelves and facings.
While we have made significant progress in our distribution gains, we are still under-indexed compared to competition.
−Removed: Our omnichannel marketing strategy is focused on building a purpose driven brand with deep connection to the community of shoppers we serve.
−Removed: We take a modern marketing approach and are constantly innovating on new ways to reach and connect with our community.
−Removed: We believe this includes a best-in-class social media strategy, a deep creator/ influencer network, and a highly strategic approach to paid media.
−Removed: With the higher costs of shipping and fulfillment activities related to our direct-to-consumer (“DTC”) business and other related costs, we will continue to shift our focus and investments towards more efficient and scalable distribution models with our current retail and digital customers.
−Removed: As we move forward beyond 2025, we will gradually transition away from Honest.com as a shipping and fulfillment channel, while ensuring the site remains a resource for educating consumers, showcasing our complete product portfolio, and driving consumers to purchase offsite.
+Added: Our marketing strategy is focused on building a purpose-driven brand with deep connection to the community of shoppers we serve.
+Added: We apply a modern, data-driven marketing approach and continuously innovate, optimize and identify new ways to reach and connect with our community.
+Added: We believe this includes a best-in-class social media and influencer marketing strategy and a highly strategic approach to paid media.
In 2023, we executed a broad-based Transformation Initiative designed to build the Honest brand and drive growth in higher-margin areas of the portfolio, strengthen our cost structure, drive focus on the most productive areas of our business, deliver greater impact from brand-building investments, and improve executional excellence across the enterprise.
−Removed: Throughout 2023 and 2024, we made meaningful progress across our Transformation Initiative Pillars of Brand Maximization, Margin Enhancement, and Operating Discipline, including delivering cost savings throughout our supply chain, optimizing our marketing spend to maximize impact, emphasizing best-selling items, and exiting the Asian, European, and portions of our sanitization business, while building a culture that emphasizes executional excellence and discipline.
−Removed: In addition, we continued our improved working capital position, including our discipline in inventory management and we executed price increases that supported Brand Maximization, recognizing the value Honest provides consumers.
−Removed: In fiscal year 2024, we improved our operating results by expanding gross margin, leveraging operating expenses and generating positive Adjusted EBITDA.
−Removed: Our strategic plan is grounded in our Transformation Initiative Pillars, which set the building blocks for long-term value creation.
−Removed: Beyond 2024, the Company expects to realize revenue growth of 4% to 6% annually and continued Adjusted EBITDA margin expansion.
+Added: On October 30, 2025, our Board of Directors approved Transformation 2.0:
+Added: Powering Honest Growth (“Powering
+Added: Honest Growth”) which builds upon our original Transformation Pillars of Brand Maximization, Margin Enhancement and Operating Discipline.
+Added: Powering Honest Growth is aimed at improving simplicity, focus and profitability, which includes exiting certain lower margin, non-strategic categories and channels, including exiting Honest.com fulfillment and apparel, as well as exiting retail and online stores in Canada, optimizing our cost structure by rightsizing selling, general and administrative expenses, and implementing supply chain efficiencies.
+Added: We expect to substantially complete the actions under Powering Honest Growth by December 31, 2026.
+Added: Our strategic plan is grounded in our Transformation Pillars, which set the building blocks for long-term value creation.
+Added: We expect to realize revenue growth of 4% to 6% annually and continued Adjusted EBITDA margin expansion.
Supply Chain and Operations
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Our third-party partners are located in various locations including the United States, Mexico and China.
−Removed: Our supply chain team manages these
−Removed: relationships and processes and, with the support of our innovation team, researches materials, components and equipment, approves and manages purchasing plans, and oversees product fulfillment.
+Added: Our supply chain team manages these relationships and processes and, with the support of our innovation team, researches materials, components and equipment, approves and manages purchasing plans, and oversees product fulfillment.
The primary raw materials and components of our products include responsibly sourced, plant-based fluff pulp in our diapers and plant-based substrate in our baby wipes, among other materials.
Just as important as what goes into our products, we actively work with suppliers to avoid certain materials, including parabens, paraffins and synthetic fragrances, that don’t meet our standards but are commonly used by mainstream brands.
−Removed: Our distribution network includes two warehouses in Nevada and Pennsylvania, respectively, with retail and DTC fulfillment capabilities and value-added services operated by National Distribution Centers, LLC, or NFI, and GEODIS Logistics LLC, or GEODIS, respectively.
−Removed: The warehouse in Las Vegas is a state-of-the-art facility leased by Honest with a focus on automated large scale DTC fulfillment.
+Added: Our distribution network includes two warehouses in Nevada and Pennsylvania, respectively, with retail fulfillment capabilities and value-added services operated by National Distribution Centers, LLC, or NFI, and GEODIS Logistics LLC, or GEODIS, respectively.
+Added: The warehouse in Las Vegas is a state-of-the-art facility leased by Honest with a focus on automated large scale retail fulfillment.
We manage inventory by forecasting demand tied to consumption and marketing campaigns, as well as analyzing product sell-through, and analyzing our supply chain to ensure sufficient capacity to support demand.
As a result of global pandemics or other macroeconomic trends, we and our distribution partners have in the past experienced and may in the future experience some supply-related disruptions to the operations of our fulfillment centers.
+Added: As part of Powering Honest Growth, i n December 2025, we notified GEODIS, pursuant to the terms of the contract, that we are terminating the agreement with them for the Pennsylvania warehouse use and services effective June 30, 2026.
+Added: Following June 30, 2026, we will only be operating with the Nevada warehouse.
The markets in which we operate are highly competitive and rapidly evolving, with many new brands and product offerings emerging in the marketplace.
We face significant competition from both established, well-known legacy c onsumer packaged goods, or CPG players and emerging DTC brands.
−Removed: Select competitors of diapers and wipes include Kimberly-Clark Corporation (maker of Huggies and Cottonelle), Procter & Gamble Company (maker of Pampers, Pampers Pure, Luvs and Charmin), WaterWipes UC and other private label brands.
−Removed: Select competitors of our skin and personal care products include Kenvue Inc.
−Removed: (maker of Johnson’s Baby and Aveeno), The Clorox Company (parent company of Burt’s Bees, Inc.), Unilever PLC (maker of Shea Moisture), Estée Lauder Inc., L’Oréal S.A.
+Added: Select competitors of our wipes include ZURU Edge Limited (maker of Millie Moon and Rascals), WaterWipes UC, DUDE Wipes, Inc., Edgewell Personal Care Company (maker of Wet Ones wipes) and other private label brands.
+Added: Select competitors of our skin and personal care products include Kimberly-Clark Corporation (pending acquiror of Kenvue Inc.), The Clorox Company (parent company of Burt’s Bees, Inc.), Unilever PLC (maker of Shea Moisture), Estée Lauder Inc., L’Oréal S.A.
and Pacifica Beauty LLC.
−Removed: Select competitors of our baby clothing include Carter's Inc.
−Removed: We compete based on various product attributes including clean formulation, sustainability, effectiveness and design, as well as our ability to establish direct relationships with our consumers through Honest.com.
+Added: Select competitors of our diapers include Kimberly-Clark Corporation (maker of Huggies diapers and Cottonelle wipes) and Procter & Gamble Company (maker of Pampers, Pampers Pure, Luvs and Charmin).
+Added: We compete based on various product attributes including clean formulation, sustainability, effectiveness and design.
We believe that we compete favorably across these factors taken as a whole.
−Removed: Our product-level point of sale consumption growth in 2024 significantly outpaced the category in wipes and baby personal care.
−Removed: Based on independent third-party consumption data for the 52 weeks ended January 5, 2025 , the point of sale consumption growth for the clean and natural products of Honest wipes and baby personal care grew 25% and 16%, respectively, significantly outpacing the products in the industry as a whole which declined in wipes and baby personal care of 3% and 1%, respectively.
−Removed: We believe that consumers' need for clean products will continue to grow in years to come and as consumers become more knowledgeable about clean credentials and our Honest Standard.
−Removed: We believe that certain historical leading brands that have produced products in these categories for decades generally focus on single categories and offer products made with conventional ingredients that are less aligned with increasing consumer preference for clean and natural solutions.
+Added: Our product-level point of sale consumption growth in 2025 significantly outpaced the category in wipes and baby personal care, while decline in point of sale consumption for diapers in 2025 also outpaced the category .
+Added: Based on independent third-party consumption data for the 52 weeks ended January 4, 2026 , the point of sale consumption growth for wipes and baby personal care was 31% and 12%, respectively, and point of sale consumption for diapers declined 15%, each significantly outpacing the products in the industry as a whole which grew in wipes and baby personal care of 5% and 3%, respectively, and declined in diapers of 1%.
+Added: We believe that consumers' need for sensitive skin products and clean products will continue to grow in years to come and as consumers become more knowledgeable about clean credentials and our Honest Standard.
+Added: We believe that certain historical leading brands that have produced products in these categories for decades generally focus on single categories and offer products made with conventional ingredients that are less aligned with increasing consumer preference for clean and naturally-derived ingredients.
We believe that given consumers’ growing focus on their health and wellness, reducing waste and promoting social impact, we are well-positioned to continue to take market share from these legacy brands.
Our Purpose-Driven Organization
−Removed: We are a personal care company on a mission to challenge ingredients, ideals , and industries so people can protect more of what they love.
−Removed: We call this the “Honest Standard” and it drives our standard for quality across the three dimensions below.
−Removed: Ingredients, Ideals, Industries
−Removed: We believe that consumers should never have to worry about the safety of the products they bring into their home.
−Removed: That’s why we rigorously test and research every product.
−Removed: We maintain a NO List™ of over 3,500 chemicals and materials we will not formulate with, including parabens, sulfate surfactants, phthalates, formaldehyde donors and synthetic fragrances.
+Added: The Honest Standard is our rigorous set of guiding principles that helps shape every step of product innovation and development, reflecting our ongoing dedication to safety, transparency and integrity.
+Added: We believe that consumers should never
+Added: have to worry about the safety of the products they bring into their home.
+Added: That’s why we ri gorously test and research every product.
+Added: We maintain a NO List™ of over 3,500 chemicals and materials we will not formulate with, including parabens, phthalates, formaldehyde donors and synthetic fragrances.
We have an in-house toxicologist and an eco-toxicologist with in-depth audit protocols.
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We meet the requirements of many independent organizations or certification authorities for several of our products.
−Removed: This includes the USDA’s BioPreferred® Program for biobased content, the National Eczema Association’s Seal of Acceptance, Environmental Working Group ( “EWG” ) Verified™, Green Seal®, the NSF/ANSI 305 standards set by Quality Assurance International, OEKO-TEX® STANDARD 100 and the Global Organic Textile Standard for organic cotton in our Honest baby clothing and bedding.
+Added: This includes the USDA’s BioPreferred® Program for biobased content, the National Eczema Association’s Seal of Acceptance, the IWSFG standard for flushable wipes, Environmental Working Group ( “EWG” ) Verified™ and OEKO-TEX® STANDARD 100.
We have over 100 EWG Verified™ SKUs across the organization, which are products that do not include EWG's chemicals of concern while also meeting their strict health-based guidelines.
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Our partnership with March of Dimes helps fund research, advocacy and service programs addressing maternal and infant mortality with critical healthcare and support.
−Removed: Through this partnership, in 2024 we have donated more than $0.7 million, reaching more than an estimated 8 million mothers with health education and programs to support the organization, including its new Mom and Baby Action Network.
+Added: Since this partnership, we have donated more than $0.8 million and reached more than an estimated 402,000 mothers in 2025 with health education and programs to support the organization, including its new Mom and Baby Action Network.
As a values-driven organization, we take a holistic approach to caring for our employees, with benefits and programs designed to support physical, mental, emotional and financial well-being.
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Our corporate social responsibility efforts provide opportunities for employees to give back to communities in need through volunteerism and donation matching.
−Removed: The Honest Company provides an Employee Assistance Program (EAP) at no cost to employees to support emotional well-being and a fitness reimbursement through Husk Wellness (formerly Global Fit Rewards) to encourage a healthy lifestyle for Honest employees.
+Added: The Honest Company provides an Employee Assistance Program (EAP) at no cost to employees to support emotional well-being and a fitness reimbursement to encourage a healthy lifestyle for Honest employees.
As of December 31, 2025, we had a total of 174 employees, all who are full-time, as well as a limited number of temporary employees and consultants.
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Our commitment to environmental mindfulness shows up through our product development, packaging processes and in many parts of our business on a daily basis.
−Removed: For example, the cartons used in our baby personal care line are environmentally-friendly, Forest Stewardship Council (“FSC”)-certified, and made from 100% recycled, PCW (pre/post consumer waste) materials.
−Removed: Our Honest.com shipping cartons are 100% PCR cardboard.
−Removed: 100% of our baby personal care bottles are recyclable or include recycled materials and we are regularly looking to increase the amount of post-consumer resin in our components.
+Added: For example, the cartons used in our baby personal care line are environmentally-friendly, Forest Stewardship Council (“FSC”)-certified, and/or made from 100% recycled, PCW (pre/post consumer waste) materials.
+Added: 100% of our full-size baby personal care bottles are recyclable or include recycled materials and we are regularly looking to increase the amount of post-consumer resin in our components.
Our diapers feature an innovative design that uses less material than our previous diaper innovation.
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These laws and regulations principally relate to the ingredients or components, proper labeling, advertising, packaging, marketing, manufacture, registration, safety, shipment and disposal of our products.
−Removed: Our cosmetic, over-the-counter drugs, food (vitamins/dietary supplements) and cleaning products are subject to regulation by the Food and Drug Administration, or the FDA.
+Added: Our cosmetic, over-the-counter drugs, food (vitamins/dietary supplements) and cleansing products are subject to regulation by the Food and Drug Administration, or the FDA.
Under the Federal Food, Drug and Cosmetic Act, or the FDCA, cosmetics are defined as articles or components of articles that are applied to the human body and intended to cleanse, beautify or alter its appearance, with the exception of soap.
−Removed: The labeling of cosmetic prod ucts is also subject to the requirements of the FDCA, the Fair Packaging and Labeling Act, the Poison Prevention Packaging Act and other FDA regulations.
+Added: The labeling of cosmetic products is also subject to the requirements of the FDCA, the Fair Packaging and Labeling Act, the Poison Prevention Packaging Act and other FDA regulations.
Cosmetics are not subject to pre-market approval by the FDA, however certain ingredients, such as color additives, must be pre-authorized.
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Inspections also may arise from consumer or competitor complaints filed with the FDA.
−Removed: In the event the FDA identifies false or misleading labeling or unsanitary conditions or otherwise a failure to comply with FDA requirements, we may be required by a regulatory authority or we may independently decide to conduct a recall or marke t withdrawal of our product or to make changes to our manufacturing processes or product formulations or labels.
+Added: In the event the FDA identifies false or misleading labeling or unsanitary conditions or otherwise a failure to comply with FDA requirements, we may be required by a regulatory authority or we may independently decide to conduct a recall or market withdrawal of our product or to make changes to our manufacturing processes or product formulations or labels.
In addition, the Modernization of Cosmetics Regulation Act (“MoCRA”), enacted in December 2022, expanded the FDA’s regulatory authority over cosmetic products, including by providing the FDA with new mandatory recall authority over cosmetics and by requiring the registration of cosmetic manufacturing facilities, the reporting of certain adverse events, the issuance of cGMP requirements and the establishment of safety substantiation requirements.
−Removed: The cGMP regulations under MoCRA are to be proposed by October 2025.
+Added: The cGMP regulations under MoCRA are yet to be proposed by FDA.
If a product is intended for use in the diagnosis, cure, mitigation, treatment or prevention of a disease condition or to affect the structure or function of the human body, the FDA will regulate the product as a drug.
−Removed: Our current products that are intended to treat acne and skin care products with sun protection factor, or SPF, are considered over-the-counter, or OTC, drug products by the FDA.
+Added: Our current products that are intended to soothe diaper rash and skin care products with colloidal oatmeal are considered over-the-counter, or OTC, drug products by the FDA.
Our OTC products are subject to regulation through the FDA’s “monograph” system which specifies, among other things, permitted active drug ingredients and their concentrations.
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The FDA may change the regulations as to any product category, requiring a change in labeling, product formulation or analytical testing.
−Removed: We are subject to regulation by the CPSC under the Consumer Product Safety Act, the Flammable Fabrics Act, the Poison Prevention Packaging Act, the Federal Hazardous Substances Act, and other laws enforced by the CPSC.
−Removed: These statutes and the related regulations establish safety standards and bans for consumer products.
−Removed: The CPSC monitors compliance of consumer products under its jurisdiction through market surveillance and has the authority to conduct product safety related inspections of establishments where consumer products are manufactured, held, or transported.
−Removed: The CPSC has the authority to require the recall of noncompliant products or products containing a defect that creates a substantial risk of injury to the public.
−Removed: The CPSC may seek civil and criminal penalties for regulatory noncompliance under certain circumstances.
−Removed: CPSC regulations also require manufacturers of consumer products to report to the CPSC certain types of information regarding products that fail to comply with applicable regulations, that contain a defect which could create a substantial product hazard, or that create an unreasonable risk of serious injury or death.
−Removed: Certain state laws also address the safety of consumer products and mandate reporting requirements, and noncompliance may result in penalties or other regulatory action.
−Removed: The USDA enforces federal standards for organic production and use of the term “organic” on product labeling.
−Removed: These laws prohibit a company from selling or labeling products as organic unless they are produced and handled in accordance with the applicable federal law.
−Removed: The FTC, FDA, USDA, EPA, and other government authorities also regulate advertising and product claims regarding the characteristics, quality, safety, performance and benefits of our products.
−Removed: These regulatory authorities typically require a safety assessment of the product and reasonable basis to support any factual marketing claims.
−Removed: What constitutes a reasonable basis for substantiation can vary widely from market to market, and there is no assurance that our efforts to support our claims will be considered sufficient.
−Removed: The most significant area of risk for such activities relates to improper or unsubstantiated claims about the composition, use, efficacy and safety of our products and their environmental impacts.
−Removed: If we cannot adequately support safety or substantiate our product claims, or if our promotional materials make claims that exceed the scope of allowed claims for the classification of the specific product, the FDA, FTC or other regulatory authority could take enforcement action, impose penalties, require us to pay monetary consumer redress, require us to revise our marketing materials or stop selling certain products and require us to accept burdensome injunctions, all of which could harm our business, reputation, financial condition and results of operations.
−Removed: In addition, the FTC regulates the use of endorsements and testimonials in advertising as well as relationships between advertisers and social media influencers pursuant to principles described in the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising, or the Endorsement Guides.
−Removed: The Endorsement Guides provide that an endorsement must reflect the honest opinion of the endorser and cannot be used to make a claim about a product that the product’s marketer couldn’t itself legally make.
−Removed: They also say that if there is a connection between an endorser and the marketer that consumers would not expect and it would affect how consumers evaluate the endorsement, that connection should be disclosed.
−Removed: Another principle in the Endorsement Guides applies to ads that feature endorsements from people who achieved exceptional, or even above average, results from using a product.
−Removed: If the advertiser doesn’t have proof that the endorser’s experience represents what people will generally achieve using the product as described in the ad, then an ad featuring that endorser must make clear to the audience what results they can generally expect to achieve and the advertiser must have a reasonable basis for its representations regarding those generally expected results.
−Removed: Although the Endorsement Guides are advisory in nature and do not operate directly with the force of law, they provide guidance about what the FTC staff generally believes the Federal Trade Commission Act, or FTC Act, requires in the context using of endorsements and testimonials in advertising and any practices inconsistent with the Endorsement Guides can result in violations of the FTC Act’s prohibition against unfair and deceptive practices.
−Removed: To the extent we may rely on endorsements or testimonials, we will review any relevant relationships for compliance with the Endorsement Guides and we will otherwise endeavor to follow the FTC Act and other legal standards applicable to our advertising.
−Removed: However, if our advertising claims or claims made by our social media influencers or by other endorsers with whom we have a material connection do not comply with the Endorsement Guides or any requirement of the FTC Act or similar state requirements, the FTC and state consumer protection authorities could subject us to investigations and enforcement actions, impose penalties, require us to pay monetary consumer redress, require us to revise our marketing materials and require us to accept burdensome injunctions, all of which could harm our business, reputation, financial condition and results of operations.
We are also subject to a number of data privacy and security obligations, including U.S.
−Removed: federal, state, local and foreign laws, regulations guidance, and industry standards related to data privacy, security, and protection that affect companies conducting business on the Internet, including consumer protection regulations that regulate retailers and govern the promotion and sale of merchandise.
−Removed: Many of these laws and regulations are still evolving and being tested in courts, and could be interpreted in ways that could harm our business.
−Removed: These may involve user privacy, data protection, content, intellectual property, distribution, electronic contracts and other communications, automatically renewing product subscriptions, competition, protection of minors, consumer protection, telecommunications, product liability, taxation, economic or other trade prohibitions or sanctions and online payment services.
−Removed: Among other laws and regulations, we are subject to federal, state, local and international laws regarding privacy and protection of people’s data.
−Removed: Foreign data protection, privacy and other laws and regulations can be more restrictive than those in the United States.
−Removed: federal and state and foreign laws and regulations are constantly evolving and can be subject to significant change.
−Removed: In addition, the application, interpretation and enforcement of these laws and regulations are often uncertain,
−Removed: and may be interpreted and applied inconsistently from country to country and inconsistently with our current policies and practices.
−Removed: In the ordinary course of our business, we may process personal or sensitive data.
−Removed: Accordingly, we are, and may in the future become, subject to numerous data privacy and security obligations, including federal, state, local, and foreign laws, regulations, guidance, and industry standards related to data privacy, security, and protection.
−Removed: Such obligations may include, without limitation, the Federal Trade Commission Act, the Telephone Consumer Protection Act of 1991, the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003, the California Consumer Privacy Act of 2018 (“CCPA”), the Canadian Personal Information Protection and Electronic Documents Act, Canada’s Anti-Spam Legislation, the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”), the EU GDPR as it forms part of United Kingdom (“UK”) law by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”), the ePrivacy Directive, and the Payment Card Industry Data Security Standard (“PCI DSS”).
−Removed: Additionally, we are, or may become, subject to various U.S.
+Added: federal, state, local and foreign laws, regulations, guidance, and industry standards .
+Added: Many of these obligations are evolving and becoming increasingly stringent, and could be interpreted and applied in ways that could harm our business.
+Added: In the ordinary course of our business, we process personal (including, at times, sensitive) data.
+Added: Obligations related to personal data include and may in the future include, without limitation, the Federal Trade Commission Act, the Telephone Consumer Protection Act of 1991, the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003, the California Consumer Privacy Act of 2018 (“CCPA”), the Canadian Personal Information Protection and Electronic Documents Act, Canada’s Anti-Spam Legislation, the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”), the EU GDPR as it forms part of United Kingdom (“UK”) law by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”), the ePrivacy Directive, various US state comprehensive consumer privacy laws, and the Payment Card Industry Data Security Standard (“PCI DSS”).
+Added: As applicable, these laws require us to include specific disclosures and afford individuals certain rights regarding their personal data.
+Added: Data protection obligations impact our business and ability to provide our products and services and create potential liability for non-compliance.
+Added: Additionally, we are subject to various U.S.
federal and state consumer protection laws which require us to publish statements that accurately and fairly describe how we handle personal data and choices individuals may have about the way we handle their personal data.
−Removed: Numerous U.S.
−Removed: states have enacted comprehensive privacy laws that impose certain obligations on covered businesses, including providing specific disclosures in privacy notices and affording residents with certain rights concerning their personal data.
−Removed: As applicable, such rights may include the right to access, correct, or delete certain personal data, and to opt-out of certain data processing activities, such as targeted advertising, profiling, and automated decision-making.
−Removed: The exercise of these rights may impact our business and ability to provide our products and services.
−Removed: Certain states also impose stricter requirements for processing certain personal data, including sensitive information, such as conducting data privacy impact assessments.
−Removed: These state laws allow for statutory fines for noncompliance.
−Removed: For example, the CCPA applies to personal data of consumers, business representatives, and employees who are California residents, and requires businesses to provide specific disclosures in privacy notices and honor requests of such individuals to exercise certain privacy rights.
−Removed: The CCPA provides for fines and allows private litigants affected by certain data breaches to recover significant statutory damages.
−Removed: Outside the United States, under the GDPR, companies may face temporary or definitive bans on data processing and other corrective actions;
−Removed: fines of up to 20 million Euros under the EU GDPR, 17.5 million pounds sterling under the UK GDPR or, in each case, 4% of annual global revenue, whichever is greater;
−Removed: or private litigation related to processing of personal data brought by classes of data subjects or consumer protection organizations authorized at law to represent their interests.
+Added: Additional obligations regarding privacy, data protection, content, intellectual property, distribution, electronic contracts and other communications, automatically renewing product subscriptions, competition, protection of minors, consumer protection, telecommunications, product liability, taxation, economic or other trade prohibitions or sanctions and online payment services continue to apply to our business.
See the section titled “Risk Factors – Risks Related to Legal and Governmental Regulation” for additional information about the laws and regulations to which we may become subject and about the risks to our business associated with such laws and regulations.
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Additionally, the Company routinely posts additional important information, including press releases, on its website and corporate LinkedIn account and recognizes its website and corporate LinkedIn account as channels of distribution to reach public investors and as a means of disclosing material non-public information for complying with disclosure obligations under Regulation FD.
−Removed: Accordingly, investors should monitor our website and corporate LinkedIn account in addition to our SEC filings and public webcasts.
+Added: investors should monitor our website and corporate LinkedIn account in addition to our SEC filings and public webcasts.
These items are available at investors.honest.com under News and Events.
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.