Patient and customer affordability

By focusing on the accessibility and affordability of our eye care services and eyewear products, we can amplify our societal impact and our business success.

Our low-cost operating model enables us to deliver exceptional value and convenience to our customers while maintaining an accessible price point and a wide selection of high-quality, affordable products. Our focus on affordability and accessibility also helps build trust as we work hard to ensure that people can see their best. Above all other considerations, we focus on our mission of providing high-quality and low-cost eye care and eyewear in decisions we make across our business.

Some of the ways we maintain our low price point include:

• We make investments in equipment and technologies to provide quality care efficiently and that enable our labs to run more cost- effectively. We are always looking for ways to increase efficiency and improve access to eye care and eyewear , and that means staying abreast of the latest technologies in both optometric equipment and lab equipment. Our efficient store operations, combined with our centralized lab and distribution centers, allow us to capably shift inventory across our network to meet customer expectations.
• The footprint of our retail stores is light. We keep our stores small relative to other retail spaces, and we seek to incorporate highly efficient lighting and heating and cooling systems to keep operating costs down.
• We do business with fewer, larger product suppliers. This helps us establish long-term relationships with product suppliers whose values align with ours and allows us to maintain our low-cost profile

Patient and customer accessibility

Remote care technology allows us to provide access to quality eye care to more patients, especially those who live in areas without easy access to an optometrist. It also has the benefit of increasing the number of appointments available in locations with a limited number of optometrists on site.

Also, as part of our remote care initiatives, we are transitioning from paper-based to electronic health records. Storing patient records electronically has the dual benefits of giving remote optometrists secure access to patient records and improving the overall patient experience. When rolling out electronic health records and remote care at our stores, we provide thorough training to all associates and optometrists.

Training is tailored to individual roles and responsibilities and ensures that patients receive the same quality of care as they would expect from an in-person appointment. We educate our associates in everything from appointment scheduling and electronic health records to assisting the remote optometrist with eye exams. Optometrists receive detailed education on the new technology and exam flow to ensure that they can confidently deliver high-quality eye care remotely.

We use a combination of electronic learning through our Learning Management System and in-store learning programs that coincide with the deployment of electronic health records and remote care capabilities. Remote optometrists have access to a full suite of technology to ensure that they have a smooth connection with their patients. This includes computers, enhanced web access and data protection software, as well as high-quality, in-store cameras and computer systems to capture detailed imagery of patients’ eyes.

These tools ensure that remote appointments are easy, safe and secure, and that patients receive the same quality of care as they would expect from an in-person optometrist.

Patient and customer experience

We want to create experiences where each patient and customer feels genuinely cared for across National Vision locations. We work hard to ensure that any optometrist associated with National Vision is well supported so they can focus on delivering the best possible care to their patients. It is critical that we continually monitor how satisfied patients and customers are with their experience.

We have set up multiple listening posts at key points in the customer journey to better understand how our customers feel about their experience with our brands. We measure our net promoter score and customer satisfaction across various customer touch points to ensure we deliver a high-quality experience that will foster new customer acquisition and retention. Customer net promoter scores, satisfaction scores and other customer survey feedback are shared with leadership teams, communicated back to associates and optometrists as appropriate, and used to inform procedural improvements across our operations where relevant.

The National Vision Customer Care Center helps patients and customers of our optical stores with questions or comments over the phone or email. We also regularly monitor and respond to inquiries on our brand social media accounts. To manage calls that come into the Customer Care Center, we have a customer service ticketing system that segments incoming customer inquiries to allow for greater efficiency in our response efforts.

In response to the feedback provided through our customer survey program, we launched a store refresh program aimed at elevating the in-store experience, including updates to store layouts and associate workspaces, ensuring a more seamless and enjoyable experience for everyone involved.

Clinical advisory panel

To keep National Vision and the doctor network up to date on innovations in the optometry space, we have a Clinical Advisory Panel of doctors who evaluate all potential products, examination equipment and clinical operating procedures before they are deployed to the optometry offices inside or next to our locations. Members of the Clinical Advisory Panel serve for one year and any optometrist practicing in the National Vision network may apply. Serving on the Clinical Advisory Panel helps doctors in the network build leadership skills and contribute positively to the patient experience.

Peer review process

Optometrists practicing in the National Vision network are required by their respective employers to adhere to their relevant state board regulations and maintain the required licenses and credentials. In collaboration with the various independent practices within the network, we have also established a peer review process to hold doctors to a consistent and high standard of clinical competence. Area Doctors, which are optometrists responsible for the training and oversight of doctors within their respective practices, assess the doctors practicing within their region. These assessments include chart audits and observation sessions to ensure that doctors are providing quality care to all patients.

Product quality and safety standards

The optical industry is highly regulated in the United States. All frames or lenses sold in our stores must meet national and state standards for quality, durability, health and safety. We also use a company-wide set of quality standards, which often exceed what is required by law, to guide the development of our products.

We communicate our quality standards to our product suppliers, and each factory we partner with must pass an annual audit with an external third party to demonstrate that they meet our quality standards. National Vision also makes every effort to purchase products from suppliers that do not contain known hazardous materials, and we use product signs and labels as required by law, such as California’s Safe Drinking Water and Toxic Enforcement Act (also referred to as Proposition 65).

National Vision is dedicated to sourcing all components and materials used to produce our private label products from product suppliers that share our values and standards regarding human rights, environmental responsibility and ethics. Our social compliance audit process assesses the health and safety practices in place at select product suppliers’ facilities and monitors practices across our factory network. Additionally, National Vision supports the goal of ending violence, human rights violations and environmental devastation through the application of our strict Conflict Minerals Policy.

Governance and management of giving programs

Our philanthropic efforts are led by our Corporate Responsibility Steering Committee, whose members include senior vice presidents across the organization, and is primarily conducted through 20/20 Quest, a National Vision sponsored charitable foundation, chartered for the purpose of providing screenings, eye exams, eyeglasses and refractive error solutions to the optically underserved in both the United States and the developing world. The National Vision Board receives regular updates on our philanthropic goals and initiatives.

National Vision Cares

Through our National Vision Cares program, we empower our stores to partner with local community organizations and non-profits to identify and address the needs of their communities. Our affiliated doctors and associates make a difference by providing vouchers for free eye exams and glasses to individuals in need, helping ensure that quality eye care is accessible to all.

Stores can request vouchers through National Vision Cares for a free eye exam and pair of glasses when they identify eligible people in the community in need of vision care who do not have vision insurance or participate in governmental healthcare programs. Recipients include those who have suffered major financial setbacks or have been affected by natural disasters.

20/20 Quest

20/20 Quest is a National Vision sponsored 501(c)(3) charitable foundation chartered for the purpose of providing screenings, eye exams, eyeglasses and refractive error solutions to the optically underserved in both the United States and abroad. In addition to financial donations, 20/20 Quest has helped people all over the world receive glasses through frame and lens donations from manufacturers, optical chains and individuals.

RestoringVision

RestoringVision is a global nonprofit organization dedicated to creating equitable access to vision services and eyeglasses for individuals living on less than $2 a day worldwide. Since 2007, National Vision has partnered with RestoringVision to advance its mission to empower lives by restoring vision for millions of people in need. We have made significant and consistent contributions through several philanthropic programs including mission trips, employee giving glasses sponsorships and in- kind donations of glasses. We also collaborate with RestoringVision on the Made Locally, Given Globally program, established in 2019. Additionally, we have played a vital role in helping the organization build a sustainable supply chain and set strategic priorities through our participation on the RestoringVision Board, including by having a 20/20 Quest representative to serve as the Chairman of the Board and our Executive Chairman, Reade Fahs, serving as a member of the Board. Learn more about RestoringVision on their website.

Through our long-time partnership with RestoringVision and Americares, we provide support to people in the U.S. who are significantly below the poverty line. Those in need can visit any of the nearly 1,000 Americares clinics and health centers across the U.S. and receive free glasses along with many other health offerings provided by Americares and its partners. Many of the clinics where the glasses were dispensed are Free and Charitable Clinics or Federally Qualified Health Centers operating on annual budgets of less than $100,000. Most of the clinics rely on volunteers and could not have supported vision programs in their clinics without this support.

Advancing optometric education

Optometrists are the heart of our business, providing the eye care services that are critical to our operation. They are also often the first touch point a patient has into the healthcare system and are able to identify a myriad of non-optical diseases, playing an important role in primary care. For this reason, we believe that actively contributing to the advancement of optometric education is essential. Since 2016, National Vision has proudly partnered with and supported optometry schools nationwide, donating millions of dollars to help cultivate the next generation of optometrists

Optometrist scholarship programs

National Vision is proud to support optometry students in their educational pursuits. Enabling the next generation of eye care professionals is key to continuing to fight the global vision crisis. In addition to supporting our associates, we award six optometry student scholarships each year.

Three scholarships are awarded through our National Vision Scholarship Program. The program is open to students at optometry schools located in the United States, Puerto Rico and Canada. To find out more about our scholarship program and application requirements, visit the National Vision Scholarship program website.

An additional three scholarships are awarded through our National Optometric Student Association scholarship program. The award is given to members of the National Optometric Student Association based on their response to a short essay prompt and their history of community service.

These scholarships are in addition to our Optometrist Tuition Reimbursement Program, which offers associates up to $20,000 for education expenses toward a Doctor of Optometry degree.

VisionSpring

VisionSpring is a social enterprise focused on bringing affordable, quality glasses to people around the world that need them. Since its founding in 2001, VisionSpring has reached millions of low-income customers.

VisionSpring’s goal is for low-income people to utilize eyeglasses to improve their daily functioning, productivity and income earning potential, which create the possibility of a more prosperous life. Our Executive Chairman, Reade Fahs, served on the Board since 2010. Learn more about VisionSpring on their website.

Through a partnership with VisionSpring and 10 other organizations, National Vision helped launch the Clear Vision Collective (CVC) in 2019, an initiative to bring together committed parties across the optical industry to set up a sustainable model for vision care. The CVC focuses on vision care in Bangladesh, screening children and adults for vision impairments and providing eyeglasses to those who need them.

International Agency for the Prevention of Blindness

National Vision is an active supporter of the global eye health agenda through membership in the International Agency for the Prevention of Blindness (IAPB), where we support important global advocacy work. Learn more about the IAPB on their website.

World Health Organization SPECS 2030

National Vision is honored to be part of the World Health Organization's SPECS 2030 (SPECS) initiative. SPECS was created to address the unmet need for glasses delivery, especially in developing countries around the world. The initiative aims to help meet the World Health Organization’s goal of a 40-percentage point increase in effective coverage of refractive error by 2030. Participation in initiatives like SPECS allows us to serve front and center in pursuing the goal of ensuring that, by 2030, everyone who needs a pair of glasses will have them.

Benefits that meet our people’s needs

Through comprehensive benefits and other types of support, we support the physical, mental and financial well-being of our people. We offer comprehensive health coverage to full-time employees of National Vision. We regularly seek feedback from associates and optometrists to ensure our plans meet their needs and to expand the proportion of our workforce benefiting from the programs, including through an annual benefits survey.

We take pride in providing a robust benefits and comprehensive wellness program designed to keep associates and their families healthy, safe and secure. Our benefits team works hard to create offerings that meet the needs of associates throughout their careers and gathers feedback regularly through benefits surveys to ensure our offerings align with their priorities.

We take a comprehensive approach when developing benefits plans, considering the physical, mental, emotional and financial well-being of associates and their families.

Health & well-being benefits

• Medical and dental coverage
• Health Savings Account (HSA) with company contribution
• Flexible Spending Accounts (FSA) — medical and dependent care FSA
• Employee Assistance Program
• Company-paid basic life insurance
• Associate, spouse and child supplemental life insurance
• Other ancillary benefits such as accident, critical care, legal and identity theft shield
• Short- and long-term disability insurance
• Paid time off and holidays
• Paid medical and parental leave
• Smoking cessation program
• Wellness program

Financial benefits

• Retirement savings programs with company match
• Associate eyewear/gift coupon
• Wellness incentive program offered to associates participating in the medical plan
• Non-tobacco user discount for those enrolled in the medical plan
• Exclusive discount program on products, facilities and services
• Scholarship program offered to associates’ children enrolling in college
• Company-paid financial wellness benefit from Goldman Sachs Ayco
• Eligible optometrists also receive two benefits, unique to their profession, from their employers – optometry license renewal reimbursement and professional liability insurance coverage.

Looking after mental health

Support Network is a robust, confidential resource that helps associates, affiliated doctors and their immediate family members seek support to address life’s challenges. Support Network provides professional counseling and referrals to address a wide array of personal and work-related concerns like anxiety, depression, marriage and relationship problems, grief and loss, substance abuse, anger management, stress and more. Users can access resources on their own time, join moderated anonymous group sessions and contact licensed clinicians 24/7 for personalized, immediate assistance. We communicate the availability of Support Network and other resources to our associates through the benefits portal, store portal, monthly newsletters and program fliers in stores so that everyone who needs to use these resources is able to do so.

Board and management oversight

Our employee engagement and well-being efforts are led by our Chief People Officer. The National Vision Board receives updates on these and other topics as part of regular organizational updates.

Listening to our associates

Employee engagement is a measure of our people’s commitment to National Vision’s mission and values. We track engagement by surveying associates and doctors within the network. Associate experience surveys provide an engagement score, among other metrics, that we use to understand the pulse of our organization and to inform employee engagement initiatives. The survey also helps us understand how we can support our people a bit more — such as through work-life balance, enhancing work processes and managing work-related stress. Doctor surveys ask for information about optometrists’ satisfaction with National Vision systems, processes and equipment. These surveys help us understand how we can better support optometrists so they can focus on patient care. Detailed survey results and data insights are available to our leadership team as a dashboard and high-level results are shared throughout the company.

Our people team provides training to leaders to ensure that they understand how to access results and data insights. Once they complete training, leaders are able to share the results of the survey with their teams in open meetings that foster conversations about the associate experience.

Other ways that our people can offer their views on the employee experience include:

• Personal conversations with managers
• Town Hall and monthly meetings
• Reaching out directly to the HR Business Partner team
• SERVE: real time chat with management and Retail Support Center staff
• Speakfully: anonymously share ideas, feedback, concerns and compliments

National Vision Crisis Relief Fund

Our Crisis Relief Fund, launched in 2019, exists to allow our people to support each other. All employee donations to the fund are matched 2:1 by National Vision. We work with a third-party vendor to manage donations, review applications and distribute resources. All donations to the fund go directly toward helping National Vision associates and optometrists in the network. Associates and doctors in the network can visit the fund’s website to determine their eligibility and submit applications for support. They can also use the site to contribute to the fund or sign up to donate through regular payroll deductions.

Supporting the optometrists in the network

Doctors play a vital role in making our mission possible, which is why we work hard to create an environment where optometrists will want to spend their entire career. We survey optometrists in the network each year to gauge their satisfaction and understand ways to enhance their experience working with us.

We provide affiliated optometrists new to the network with opportunities for formal mentorship each year. These mentorship meetings cover a range of topics including efficiency improvements, tips for handling challenging cases, information on available products for low-income patients and opportunities to meet with senior leadership and peers.

As a doctor-centric organization, we’re always trying to think of ways to support the optometrists practicing inside or next to our locations to deliver the best patient care possible. Our Clinical Services team includes a team of Regional Clinical Directors that provide additional support and guidance. Regional Clinical Directors are highly skilled clinicians that enhance the support available to optometrists across the network. The role also provides an opportunity for the Regional Clinical Directors to explore careers in clinical administrative leadership.

Occupational health and safety

Our health and well-being efforts are built on a foundational commitment to the safety of associates and doctors in the network. We comply with all Occupational Safety and Health Administration guidelines and state regulations. At each of our labs and distribution centers, there are specific leaders responsible for the management of associate safety. For example, lab directors organize and run safety trainings for local associates, some of which are conducted virtually and others through in-person instruction. For retail locations, we provide support to managers and field leaders in understanding and complying with all applicable laws and regulations.

Our approach to managing our environmental impact focuses on improving the efficiency of our operations while retaining our position as an affordable provider of eye care and eyewear. As one of the largest optical retailers in the U.S., National Vision’s footprint includes more than 1,200 stores in 38 states and Puerto Rico. We use a highly efficient mix of domestic, company-operated processing facilities and outsourcing where necessary. We have state-of-the-art lens processing capabilities in our geographically distinct, company-operated production facilities in Lawrenceville, Georgia; St. Cloud, Minnesota; Plano, Texas; and Salt Lake City, Utah. We utilize third-party carriers to transport products from the distribution center to customers and store locations.

Facility environmental standards

Environmentally conscious decision-making not only helps us conserve resources and reduce costs, it also helps us improve the customer experience and provide safe workspaces for associates and doctors practicing in our locations. Nearly all of our facilities are in leased spaces, which influences the kinds of environmental considerations we can prioritize. We have a set of environmental standards that we apply to our retail facilities for the setup and maintenance of our stores.

These include:

• Prioritizing the use of dimmable LED lighting, motion sensors, smart controls and energy-efficient heating, ventilation and air conditioning (HVAC) systems to reduce our energy footprint
• Installing low-flow toilets and taps to reduce water consumption
• Selecting ceiling tiles made of recycled materials
• Purchasing green label certified carpet
• Applying window tinting to promote efficient energy usage, reduced glare and reduced HVAC costs
• Applying low or zero volatile organic compounds (VOC) paints
• Keeping the footprint of our stores small where possible, which reduces overall energy use for heating and cooling

Energy and emissions

A strong understanding of our environmental performance helps us identify the most effective ways to enhance our efficiency and reduce our impact. National Vision uses energy across its stores, distribution centers, labs and corporate offices. Energy used is in the form of electricity purchased from the local grid or fuels combusted on site, such as using natural gas to produce heat via a boiler or furnace. When sourced from fossil fuels, our energy use creates GHG emissions. We are committed to tracking our GHG emissions with a view to reducing these emissions over time.

We prepare and publish a GHG inventory annually, per a process defined in our GHG Inventory Management Plan. Our GHG inventory focuses on National Vision’s Scope 1 and 2 emissions for the calendar year. CO2 (carbon dioxide), CH4 (methane) and N2O (nitrous oxide) emissions are included for stationary and mobile combustion, and electricity consumption. Fugitive emissions are unintentional releases of greenhouse gasses from equipment or infrastructure. The fugitive emissions that are measured and included in our inventory come from air conditioning systems and heat pumps at our facilities. Relevant HFCs (hydrofluorocarbons) are included for refrigerant leakage emissions. In addition to those emissions required by the Greenhouse Gas Protocol, our inventory includes optionally reported fugitive emissions of HCFC-22. All air conditioning units before 2010 are assumed to use R22 as a refrigerant, while all air conditioning units sold after 2010 are assumed to use R410.

Global warming potential values are sourced from the Intergovernmental Panel on Climate Change Sixth Assessment Report (AR6). Emissions factors for electricity and fuels were sourced from the U.S. Environmental Protection Agency. Emissions factors for refrigerants were sourced from the U.K. Department for Environment, Food and Rural Affairs.

When compiling our GHG inventory, we use quality assurance and outlier analysis methods to identify data irregularities and enhance data integrity where required.

Enhancing energy efficiency

Most of our Scope 1 and 2 emissions are related to energy use at our facilities, and we are committed to doing what we can to reduce facility emissions. We understand that energy efficiency investments can both reduce emissions and lower costs. We have an energy efficient lighting upgrade program to retrofit our facilities.

We started by upgrading the facilities that use the most electricity — our distribution centers and labs. With our distribution centers and labs upgraded to energy efficient lighting, we are now focused on expanding our efficient lighting program in retail stores.

Waste management

Much of our waste management is handled by third parties due to the nature of the lease agreements for National Vision stores. We make an effort to divert waste from landfill, including by recycling where it is possible.

Some of the waste generated in our labs results from the creation of prescription lenses. We purchase blank polycarbonate, plastic and high-index lenses that are about the size and shape of a hockey puck and grind each blank into the right shape for individual prescription lenses. The excess material is called swarf and historically has been sent directly to landfill.

Across our labs, briquetters improve our management of swarf. Briquetters are machines that collect polycarbonate waste and press it into compact briquettes that are one-twentieth of the size of the starting material. These can be hauled away by our waste management partner more efficiently, and any material that we are unable to recycle takes up significantly less space in landfills.

Management of swarf is an ongoing challenge, and we continue to look for ways to improve the diversion of waste generated by our operations. Swarf is just one opportunity area for us as we enhance waste management across our operations. Looking ahead, we plan to complete waste audits at key facilities to inform a targeted waste management strategy for National Vision as a whole.

Waste diversion

Our waste reduction efforts are focused on the areas where we have the most control: our labs and distribution centers. We are committed to continuously improving waste diversion rates at all our sites, using strategies informed by thorough reviews of our operations. Based on the insights from a waste audit at our most representative location, the Lawrenceville lab, we have applied these learnings to implement improvements across our operations.

Key focus areas for improvement include:

• Enhancing signage and labeling of waste and recycling containers: To ensure everyone knows what can be recycled and where to do so, we’re making our labeling clearer and more accessible.
• Addressing “hotspots” in our production process: We’ve identified areas where cardboard and plastic recycling aren’t being separated properly and are working to address this.
• Implementing simple process improvements: By ensuring that containers are available at key steps in the production process, we’re making it easier to sort materials correctly, which will help improve recycling rates across our lab facilities.

Water use

National Vision is not a significant user of water across most of our operations, but we believe in acting as good stewards of natural resources regardless of the scale of our use. We continuously improve the water-intensive aspects of our operations to reduce our impact on local water systems.

One of the most impactful initiatives has been the installation of closed-loop coolant technology that we use with our lens manufacturing equipment.

The process of manufacturing lenses relies on the use of water as coolant while shaping lenses to the prescription and shape that a customer requires. Historically, this water would have been filtered and sent to a drain. Since 2014, National Vision labs have been implementing closed loop systems where coolant is filtered and then re-used — helping reduce water use by as much as 30% per surfaced job.

A “surfaced job” refers to the process of cutting and polishing a pair of blank lenses to create a prescription. Approximately two thirds of all glasses that we produce are surfaced. The remaining lenses are referred to as “single vision finished,” which means that we purchase lenses that are already cut and polished to a prescription, and our lab only cuts them to the proper shape and size to fit into a frame.

At our St. Cloud, Minnesota lab, for example, a pair of prescription lenses that are surfaced in our labs today use approximately one gallon less water than a pair manufactured before we implemented water-reduction measures.

Understanding climate-related issues

Like all businesses, National Vision may be affected by policy and market shifts to a lower-carbon economy, and by ongoing climate-related impacts such as extreme weather and longer-term changes in climate conditions. We’ve used the Task Force on Climate-related Financial Disclosures (TCFD) recommendations to formalize our understanding and disclosure of the most important climate-related issues.

Responsibility for managing climate-related risks and opportunities is shared between multiple functions of our business. Our Corporate Responsibility Council develops and refines our SEE+G framework and strategic objectives. The Corporate Responsibility Steering Committee reviews these plans and approves strategic objectives. The Steering Committee also reports up to the Nominating and Corporate Governance Committee of the Board of Directors, who is responsible for reporting to the rest of our Board on emerging ESG risks and opportunities, including climate-related risks and opportunities that are identified elsewhere in the business.

Our executive team is responsible for the day-to-day management of risk and the implementation of our strategies that address risks and opportunities. See our latest sustainability report for more detail on ESG-related governance, including governance of climate-related risks and opportunities.

The Audit Committee of our Board oversees the enterprise risk management process and is responsible for reviewing National Vision’s internal controls, financial statement integrity, compliance programs, fraud risk, legal matters and other risk areas. As a part of the enterprise risk management process, we consider risks and opportunities that relate to climate change. Through this process, National Vision improves its understanding of the company’s risk exposure, which enables it to establish procedures to help assess and manage risk.

We have developed an understanding of our most important climate-related risks and opportunities, which we continue to integrate into our SEE+G framework. Transition risks are related to the transition to a lower-carbon economy. National Vision is exposed to some degree of transition risk because our operations and supply chain create GHG emissions.

National Vision is not a carbon-intensive business, and our relatively small footprint limits our exposure to the legal, technology, market and reputation risks indicated by the TCFD. We have identified that improving resource efficiency is the best way to further insulate our business from transition risks, and our strategy is focused on measuring and managing energy use, water use and waste production. Physical risks include the direct effects of extreme weather and longer-term climate shifts. These risks may affect the operation of our stores and other physical facilities, and we have incorporated weather-related issues into risk management and business continuity planning. We recognize that physical risks may impact our supply chain, and by extension our own business, and are working to incorporate these risks into supplier engagement practices into the future.

Defining our processes and procedures to understand and respond to climate-related risks and opportunities is an ongoing effort for National Vision. We aim to reduce our environmental impact and limit exposure to climate-related risks that could negatively impact our business. At the same time, we are exploring ways to capture climate-related opportunities.

Our Board of Directors is composed of directors with a range of expertise, including individuals with optical and specialty retail industry experience. We maintain strong institutional director knowledge through regular senior management engagement, annual Board and committee self-evaluation and discussion, consistent regulatory updates and access to continuing education. The Board has three standing committees: Nominating and Corporate Governance, Compensation, and Audit. The majority of the directors on the Board are independent, and all members of Board committees are independent directors.

Our Corporate Governance Guidelines sets out expectations on matters including, but not limited to, the role and responsibility of the Board, Board composition, structure and policies, and expectations of directors. Each committee of the Board has its own charter. As noted in its charter, the Nominating and Corporate Governance Committee has oversight responsibilities with respect to corporate responsibility, sustainability and ESG topics. The Corporate Governance Guidelines are reviewed as needed by our Board of Directors and revised to ensure alignment with emerging best practices. The Corporate Governance Guidelines and committee charters are regularly reviewed and updated as needed.

Our Corporate Governance Guidelines, charters for the Audit, Nominating and Corporate Governance, and Compensation committees and other corporate governance information are available in the investors section of our website. Further details related to our corporate governance, including structure and composition, stockholder engagement, director biographies and oversight of risk management are available in our most recent Proxy Statement. Our approach to corporate governance includes regular review of policies and procedures to adapt to evolving market expectations and foster ethical conduct throughout National Vision. We are continuously updating governance practices to promote independence, accountability and effectiveness in the boardroom.

In line with shareholder approval of an amendment to our certificate of incorporation, we have phased out the classified structure of our Board. Beginning with the 2024 Annual Meeting, all directors have been elected annually. Finally, the Compensation Committee of the Board has implemented the Incentive Compensation Recovery Policy, fully compliant with SEC and Nasdaq requirements.

Enterprise risk management

Risk assessment and management involves identifying key risks across various areas of the business, assigning risk owners, and ensuring appropriate monitoring, controls, or mitigation measures are in place. The process also provides collaboration opportunities between internal audit, legal, and compliance teams, who engage with leadership and VPs to gather feedback. These discussions are essential for documenting risks specific to different business units or geographies. Top and emerging risks identified through the process are regularly reviewed by company leadership.

To manage third-party risks, we maintain a comprehensive inventory of suppliers, which is evaluated based on factors such as total spend, industry-specific risks, location, and data privacy practices. Suppliers are ranked according to their relative risk, and this information is used to inform decision-making throughout the contracting process.

Our risk assessment and third-party risk management processes complement our social compliance audit program, which has been conducted annually since 2016. Using Sedex, we track the progress of our supplier audits and review external assessments of risk associated with our product suppliers. Sedex is a globally recognized data platform that helps us gain visibility into our suppliers’ practices, track supplier performance against our audit framework and assess social and environmental risk in our supply chain. The platform also supports our partners through the supply chain, enabling our vendors to share audit data as they see fit.

Board oversight of ESG

We recognize the critical importance of integrating ESG throughout the company. We have included ESG considerations in our corporate governance documents, including Board committee responsibilities and activities. The Nominating and Corporate Governance Committee oversees our ESG strategies, policies, goals, initiatives and programs, including the implementation of our SEE+G activities and the review of our annual Sustainability Report. The committee met four times in 2024 to oversee our SEE+G initiatives. More information about our Board of Directors and their activities can be found in our latest Proxy Statement.

ESG-related governance

To help drive progress on our SEE+G focus areas, we maintain a corporate responsibility organizational structure with executive leadership starting with the Chief Executive Officer and oversight coming from the Nominating and Corporate Governance Committee of the Board of Directors. The Compensation Committee oversees the development and implementation of human capital management, succession and executive compensation plans, including consideration of emerging ESG trends and best practices. The Audit Committee is responsible for overseeing the company’s enterprise risk management program, which includes ESG topics such as cybersecurity and data privacy.

From there, responsibility cascades down through the company with our Corporate Responsibility Steering Committee, Corporate Responsibility Council and working groups with dedicated strategies. Our Chief Legal & Strategy Officer serves as executive sponsor of our SEE+G strategy, chairs the Corporate Responsibility Steering Committee and provides regular updates to the Nominating and Corporate Governance Committee and Board.

The Corporate Responsibility Steering Committee is made up of senior management members and meets several times a year to discuss initiatives and hear progress reports from the Corporate Responsibility Council. The Council, composed of leaders from various business departments including operations, finance, supply chain, merchandising and others, reports to the Steering Committee and works on prioritizing ESG issues and impact. The Council improves strategies, performance and disclosure and shapes the evolution of our ESG strategy and agenda while also providing management and oversight of the working groups

Code of Conduct

At National Vision, our Code of Conduct (the Code), reflects our commitment to the highest standards of ethical business conduct. The Code plays a vital role in fostering a culture of integrity, from the Board through executives, to all associates. All new hires receive training on the Code, and can reference the document regularly through their Associate Portal or Store Policy Manuals. The document covers a range of topics including integrity and compliance, nonretaliation, discrimination and harassment, fair labor standards, protecting customer information, marketing, conflicts of interest, anticorruption, and government and media relations. The Code of Conduct requires that all company personnel conduct their activities in full compliance with all applicable anticorruption laws, including without limitation, the U.S. Foreign Corrupt Practices Act. Our Board is charged with reviewing the Code of Conduct at least annually.

Ethics and compliance

National Vision is committed to conducting all aspects of its business in accordance with the highest legal and ethical standards. From onboarding onward, we emphasize that each associate and affiliated doctor has an essential role to play in promoting an environment where ethical and compliant behavior and integrity thrive.

During onboarding, new associates are provided access to a copy of the Code as well as training on topics including how to spot and address sexual harassment in the workplace; complying with the Health Insurance Portability and Accountability Act (HIPAA) and Americans with Disabilities Act; how to identify and avoid phishing campaigns; anti-corruption materials; and an introduction to National Vision’s health and safety standards. We use an online platform to conduct annual refresher training on select ethical topics and introduce new topics as needed.

We actively encourage our associates and affiliated doctors to speak up when they have questions or concerns related to ethical conduct by:

• Maintaining an open-door policy where associates are empowered to approach their supervisor, human resources, the legal department or the compliance officer directly
• Offering an ethics telephone hotline to all associates through various internal communications and on our internal website portals
• Reinforcing our Whistleblower Policy which emphasizes zero tolerance for any discrimination or retaliation against whistleblowers

Reported concerns are monitored by the National Vision human resources and compliance teams who work in close collaboration to follow up and address concerns. Our compliance officer provides a quarterly report to the Audit Committee of the Board, which includes a summary of the number and nature of any submissions through the hotline.

Complaint procedure

National Vision contracts with an independent third-party company, Speakfully, to serve as a communication channel between management and associates and contractors. Associates and contractors may use Speakfully’s Compliance Helpline to ask questions, seek guidance, or report concerns anonymously and confidentially. Speakfully is available 24 hours a day, 365 days of the year

Data privacy and security

Maintaining robust data security and privacy practices enables National Vision to collect, organize and protect patient and customer information, while also safeguarding company intellectual property and employee data. As a retailer, healthcare provider and employer, we must manage our own customer, patient and employee data. We also are a business associate and practice manager to optometry practices; therefore, we also must manage confidential patient records and employee information for those optometry practices. We are dedicated to protecting all patient, customer, associate and company information and we strive to adhere to all applicable laws and regulations. More information about how we collect, use, share and safeguard patient information may be found in our HIPAA Notice on the National Vision website.

Our Chief Technology Officer (CTO) oversees our approach to data security and cybersecurity and serves as part of the National Vision senior leadership team. The Vice President of Information Technology Infrastructure collaborates with the CTO and a supporting team to maintain and update the company’s technology infrastructure and corresponding safety measures. The CTO reports quarterly to the Audit Committee of the Board, covering the present state of data security and cybersecurity efforts at National Vision, introducing emerging risks and challenges, and outlining next steps for the team.

National Vision has a Privacy Policy that outlines how and why we collect, use, share and maintain consumer information and an internal Cybersecurity Policy to establish consistent data safeguards across our facilities. The data privacy security and cybersecurity space is rapidly evolving and our team strives to align National Vision’s policies and processes with the most updated laws, regulations and best practice standards. Our framework aligns with the National Institute of Standards and Technology cybersecurity framework.

Our data security team oversees and implements many security controls to minimize the risk or impact of any breach or unauthorized disclosure of our confidential and sensitive data, including protected health and personal information. These controls include industry leading endpoint protection and response software (anti-virus), network intrusion detection devices, a robust vulnerability management program, IT and third-party risk management programs and multifactor authentication.

National Vision provides annual security awareness training for corporate and store associates via the centralized Learning Management System. Training covers general security awareness topics such as social engineering threats, safe internet browsing, password security, sensitive data handling (including personal health information), physical security and privacy rules for any associate processing patient and customer credit cards.

Furthermore, the National Vision data security team administers monthly phishing testing and training to associates who have access to a company email address. The security of the National Vision network is monitored 24x7x365 by a Security Operations Center (SOC). The data security team and SOC consistently work to prevent realization of any attacks by threat actors. National Vision also conducts third-party HIPAA risk assessments to identify and catalog any potential risks to health data. Our CTO collaborates with our information security team to conduct periodic table-top exercises and testing of our data security, incident response policies and procedures.

We also periodically conduct exercises with an external partner to stress test our data security systems and practice companywide response tactics. These efforts help National Vision identify possible data security vulnerabilities, which our data security team then work diligently to address and strengthen those areas of our security infrastructure. If any significant risks are identified, they are remediated in a timely manner.

In addition to managing our data security programs and communicating standards to associates across all National Vision facilities, the data security team leads efforts to identify opportunities to digitize recordkeeping, improve workflows and increase efficiencies. The team goal is to simplify the patient and customer experience and make it easier for our associates to do great work.

Understanding supply chain ESG risk

We are focused on enhancing our understanding of environmental and social issues across our supply chain. The nature and significance of these issues vary according to supplier categories, which include:

• Product suppliers: Manufacture and provide us with frames, contact lenses or eyeglass lenses (a mix of U.S. and overseas suppliers)
• Facility suppliers: Provide equipment, cleaning, maintenance and other services for our distribution centers, labs and stores (predominantly U.S. suppliers)
• Corporate suppliers: Provide office supplies, consulting and other services that support our corporate operations (predominantly U.S. suppliers)

More environmentally sustainable products

National Vision is dedicated to providing customers with sustainable, cost-effective options. Through strong partnerships with suppliers, the company is focused on reducing its environmental footprint by offering products made from biobased and recycled materials. As National Vision continues to explore new supplier capabilities and sustainability opportunities, it is committed to amplifying the positive impact of its eco-friendly product offerings.

Supply chain management

We provide product suppliers with a copy of our Supplier Code of Conduct (Supplier Code), which is also publicly available on our website. Our supplier Code of Conduct lays out expectations for supplier management for ethics, labor, the environment, health and safety, and related management systems. This document focuses on the minimum expectations for every supplier we partner with. We provide the supplier Code of conduct to each of our suppliers when signing a contract and request that all our product suppliers provide written attestations of their understanding. Product suppliers that have access to our networks are required to complete a security assessment as well as provide any industry certifications they have, and we make it a contractual requirement for these suppliers to have adequate privacy programs in place.

Before entering into contractual arrangements with product suppliers in regions outside the U.S. and Europe, we conduct on-site visits with each potential supplier. This helps establish a good foundation on which to develop trusting and respectful relationships. We partner with a third-party provider to conduct social compliance audits of key product suppliers on an annual basis. Representatives from the third-party provider conduct interviews with employees and walk through the facility as part of the audit process. Through the audits, product suppliers are assessed for compliance with National Vision standards for health, safety and labor as outlined in the Supplier Code, as well as compliance with country-specific regulations.

Each audited supplier receives a score based on the results of the audit. The score corresponds to a color-ranking system composed of four groups scaled from no violations through multiple, critical violations. If an audited supplier scores below a certain threshold on the social compliance audit, a corrective action plan is created that specifies the concerns that should be addressed within a specific timeframe. After the timeframe passes, a representative from the third party revisits the facility to ensure correct implementation of the fix.

If a supplier does not address concerns surfaced through the audits within the required timeframe, the supplier’s agreement is subject to termination. Our compliance officer reports annually on the social compliance audit process and outcomes to the Audit Committee of the Board.

Conflict minerals policy

While conflict minerals are not typically an input for any of the products or services provided by National Vision, we maintain a Conflict Minerals Policy with which we require all factories that manufacture our direct import frames to comply.

To ensure compliance with this policy, our suppliers confirm annually that they are not using conflict minerals and provide legal documentation as evidence to that claim. The Conflict Minerals Policy may be accessed on our website.