Transparency in Supply Chains

This statement outlines our commitment to ethical practices in the supply chain, specifically addressing the risks of forced labor, slavery, and human trafficking. In compliance with laws such as the California Transparency in Supply Chains Act of 2010, we disclose the measures we have put in place to identify and mitigate these risks. Our approach focuses on responsible sourcing, supplier conduct, and ensuring that all partners adhere to clear ethical standards.

Social Compliance Program

At the core of our efforts is a comprehensive social compliance program that sets clear expectations for suppliers. These standards require compliance with labor laws, ethical conduct, and legal requirements, helping reduce the risk of exploitative practices in the supply chain. Suppliers failing to meet these expectations may face corrective actions, including removal from our approved supplier list if they do not resolve the identified issues.

Supplier Verification and Risk Assessment

Before beginning production, we verify our suppliers’ operations to ensure compliance with ethical standards. Suppliers are required to disclose their manufacturing locations, both domestic and international, enabling us to conduct thorough evaluations. We perform risk assessments using credible data sources such as global governance indicators, trafficking risk reports, and audit histories. These assessments help determine any elevated risks associated with specific suppliers or regions, ensuring that production activities are carefully considered before approval.

Ongoing Monitoring and Auditing

We maintain continuous monitoring through a structured auditing process, using a risk-based approach. Higher-risk areas receive more scrutiny, with audits conducted regularly by independent third-party organizations to ensure objectivity. These audits include facility inspections, interviews with workers and management, and reviews of operational records. When issues are identified, corrective actions are implemented promptly to address any concerns related to labor practices or compliance with ethical standards.

Supplier Acknowledgement of Compliance

All suppliers must formally acknowledge their commitment to legal and policy compliance. Our agreements with suppliers include clear expectations that all relevant laws and our internal policies will be followed. This ensures that compliance is an ongoing responsibility and not just a one-time requirement. Every transaction reinforces this commitment, helping maintain consistency and accountability across our supply chain.

Internal Accountability and Reporting

We provide clear guidelines to individuals who engage with suppliers, ensuring that responsible and ethical sourcing practices are followed. Employees have access to channels for reporting concerns or potential violations, allowing us to address issues swiftly and appropriately. This framework fosters transparency and encourages strict adherence to ethical sourcing policies.

Education and Training

To strengthen our commitment to ethical practices, we conduct regular training sessions to raise awareness of modern slavery and human trafficking risks, especially among teams involved in sourcing and supplier management. These training programs ensure that employees understand their role in preventing unethical practices and that they are familiar with our broader conduct standards, which emphasize working only with suppliers who demonstrate a strong commitment to responsible operations.

Ongoing Commitment and Future Updates

Through the combination of structured verification, independent audits, supplier accountability, and continuous training, we aim to reduce risks and promote fair working conditions throughout our supply chain. As regulations and industry standards evolve, we will review and update our practices to ensure compliance with legal requirements and maintain a transparent and responsible approach to global sourcing.