x	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.

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1.	Implement and communicate to their personnel and suppliers a Conflict Minerals policy that is consistent with our Conflict Minerals Policy;

2.	Familiarize themselves with the Conflict Minerals Rule and the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (the “OECD Guidance”);

3.	Put in place procedures for the traceability of 3TG, working with their suppliers as applicable;

4.	Where possible, source 3TG from smelters and refiners validated as being conflict free;

5.	Maintain reviewable business records supporting the source of 3TG;

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6.	From time to time, at our request, provide us with written certifications and other information concerning the origin of 3TG in products, components and parts supplied to us and the supplier’s compliance with the Conflict Minerals Policy generally;

7.	Adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with the Conflict Minerals Policy;

8.	Otherwise establish policies, due diligence frameworks and management systems that are consistent with the OECD Guidance; and

9.	Require their direct and indirect suppliers to adopt policies and procedures that are consistent with our Conflict Minerals Policy.

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1.	OECD Guidance Step One: “Establish strong company management systems”

a.

We have a team of senior staff that is responsible for our 3TG compliance program. Leadership of the compliance program resides with our Chief Compliance Officer. The following functional areas are represented on the working group: Finance, Internal Audit, Legal, Social Compliance and Sourcing. Selected internal personnel are educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. In addition, we utilize specialist outside counsel to advise us in connection with our Conflict Minerals Rule compliance and a service provider (the “Service Provider”) to, on our behalf, engage in supplier outreach and follow-up, validation of supplier responses and electronic storage of supplier responses. Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider on our behalf.

b.	We communicate our Conflict Minerals Policy internally and externally to suppliers, in each case in writing. The Conflict Minerals Policy is available on our website at http://investors.guess.com/conflict-minerals-policy.

c.	We use the then latest version of the Conflict Minerals Reporting Template (the “CMRT”) developed by the RMI to identify smelters and refiners in our supply chain.

d.	The Service Provider maintains on our behalf business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database. This information is retained for at least five years.

e.	We have a mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy, either through an email hotline or directly to our Social Compliance Department. The email address is conflictminerals@guess.com.

2.	OECD Guidance Step Two: “Identify and assess risk in the supply chain”

a.

The Service Provider, on our behalf, requests by email that the suppliers provide us with information, through the completion of a CMRT, or an online version thereof hosted by the Service Provider, concerning the usage and source of 3TG in the suppliers’ products that we identify as potentially being in-scope, as well as information concerning their related compliance efforts. The Service Provider follows up by email or phone with all suppliers that do not respond to the request within the specified time frame. If a supplier is non-

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b.

We and the Service Provider review the responses received from in-scope suppliers. The Service Provider reviews the responses received for plausibility, consistency and gaps. It follows up by email or phone with suppliers that submit a response that triggers any one of seven specified quality control flags. To the extent that a supplier reports that the potentially in-scope products it sells to us do not contain 3TG, we review that conclusion against the materials content of the products. If we have questions concerning a supplier’s conclusion, we request that it submit a revised CMRT.

c.

To the extent that a completed CMRT identifies a smelter or refiner, the Service Provider reviews the information provided against the list of Conformant smelters and refiners published in connection with the RMI’s Responsible Minerals Assurance Process (the “RMAP;” formerly the Conflict-Free Smelter Program), the London Bullion Market Association (“LBMA”) Good Delivery List and the Responsible Jewellery Council’s (“RJC”) Chain-of-Custody Certification.

d.

To the extent that a smelter or refiner identified by an in-scope supplier is not listed as Conformant, the Service Provider attempts to contact that smelter or refiner to gain information about its sourcing practices, including origin and transfer, and to determine the source and chain of custody of the 3TG. Internet research is also performed to determine whether there are any outside sources of information regarding the smelter’s or refiner’s sourcing practices.

e.

If a supplier is unable to provide information concerning the processors of 3TG in its supply chain, the Service Provider requests information on the supplier’s suppliers of products or components which may have required 3TG for their functionality or production (“Tier 2 suppliers”). The Tier 2 suppliers, and subsequent tiers of suppliers as identified to the Service Provider, are then contacted by the Service Provider.

3.	OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks”

a.	Our 3TG compliance team reports the findings of its supply chain risk assessment to our General Counsel.

b.	Our risk mitigation strategy allows for a flexible response that is commensurate with the risks identified.

4.	OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain”

5.	OECD Guidance Step Five: “Report on supply chain due diligence”

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1.

The Service Provider sent requests to 452 Suppliers to provide us with a completed CMRT. We or the Service Provider followed up by email or phone with the Suppliers that did not provide a response within the time frame specified in the request. Approximately 80% of our Suppliers responded to the Service Provider’s request for information. Many of the Suppliers that did not respond are not continuing Suppliers.

2.

The Service Provider, and in certain cases we, reviewed the responses received from the Suppliers for plausibility, consistency and gaps. The Service Provider followed up by email or phone with Suppliers that submitted a response that triggered any one of seven specified quality control flags. To the extent that a Supplier reported that a potentially in-scope product it sold to us does not contain 3TG, we reviewed that conclusion against the materials content of the product.

3.	With respect to those completed CMRTs that identified a smelter or refiner, the Service Provider reviewed the information provided against the list of Conformant smelters and refiners published by the RMI.

4.	With respect to those Suppliers that were unable to provide information concerning the processors of 3TG in their supply chains, the Service Provider requested information on the Supplier’s Tier 2 suppliers. The Tier 2 suppliers, and subsequent tiers of suppliers as identified to the Service Provider, were then contacted by the Service Provider.

5.	Our 3TG compliance team reported the findings of its supply chain risk assessment to our General Counsel.

6.

In addition, to mitigate the risk that the necessary 3TG contained in our in-scope products directly or indirectly finance or benefit armed groups in the Covered Countries, we furnished the Suppliers with written communications discussing the Conflict Minerals Rule, the OECD Guidance and our compliance requirements. In addition, we made available to the Suppliers free access to a multi-industry Conflict Minerals Resource Center site operated by the Service Provider.

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1.	Engage with Suppliers that provided incomplete responses or that did not provide responses for 2017 to encourage them to provide requested information for 2018.

2.	Monitor and encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2017 that the source of 3TG was unknown or undeterminable.

3.	Communicate to new potentially in-scope suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them. In addition, as new in-scope suppliers are added, work with these suppliers to ensure that they understand the requirements of the Conflict Minerals Rule and the OECD Guidance.

4.	Encourage our suppliers to source responsibly, particularly when sourcing from the Covered Countries.

5.	Monitor selected industry initiatives to identify smelters and refiners in the supply chain.

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(a)

The refiner listed in the table was identified by the Suppliers as being part of our 2017 supply chain. The refiner listed above is not the only smelter or refiner in our 2017 supply chain, since most of our Suppliers provided information at a company level (meaning for all of their products, rather than specific to the products that they sold to us), and because not all of our Suppliers responded to our inquiries.

(b)	All information in the table is as of April 23, 2018.

(c)	“Conformant” means that the smelter or refiner was conformant with the RMI’s RMAP assessment protocols including through mutual recognition, and those indicated as “Re-audit in process.” The listed refiner was not necessarily Conformant for all or part of 2017 and may not continue to be Conformant for any future period.

(d)	The compliance status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us.

(e)	Country location is the location of the smelter or refiner and is based solely on information made publicly available by the RMI without independent verification by us.