California Transparency in Supply Chains Act (SB 657)
Effective January 1, 2012, the California Transparency in Supply Chains Act (SB 657) requires large manufacturers and retailers to disclose their efforts to eliminate slavery and human trafficking from their supply chains. The purpose of the law is to inform consumers, allowing them to make knowledgeable choices by supporting companies that prioritize ethical supply chain management.
Verification We are dedicated to ensuring fair labor practices throughout our supply chain. We continuously work to identify, assess, and address risks related to human trafficking in the production of our products. When partnering with suppliers, we assess potential risks based on several factors, including site visits, the geographic location of suppliers, workforce profiles, and the historical presence of human trafficking in the industry. While we do not use third-party verifiers, our internal risk management team conducts assessments using a custom-developed rubric. However, we currently cannot verify whether our subcontractors utilize labor brokers.
Audits Our internal audit team performs scheduled audits of our direct suppliers to ensure they comply with our anti-slavery and human trafficking standards. These audits involve both individual and group interviews with management and supervisors, as well as site inspections.
Certification To ensure compliance with our labor standards, we require contractors and suppliers to certify that they will adhere to all applicable local, state, and federal laws, including the prohibition of child labor, prison labor, indentured labor, bonded labor, and any form of corporal punishment or physical coercion. In cases where no local or national law applies, we define “child” as anyone under the age of 15. If local laws set the minimum age below 15 but meet International Labor Organization exceptions, the lower age will apply. We reserve the right to request documentation from contractors and suppliers to verify their compliance.
Internal Accountability We have established internal accountability procedures for employees and contractors who fail to meet our standards related to slavery and human trafficking. When non-compliance is identified, we issue a formal written notice and provide a specified period for corrective actions to be taken.
Training While we do not currently offer specific training for employees and contractors on human trafficking and slavery, we are in the process of developing training programs that will be implemented in the future.