Policies

California Transparency in Supply Chains Act

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) requires retailers and manufacturers of a certain size doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains.

As part of our commitment to social responsibility, we have established Standards for Supplier Conduct. The standards cover topics including compliance with laws, voluntary labor, labor hours, hiring and employment practices, compensation, freedom of association and collective bargaining and the environment. We expect our suppliers to comply with legal requirements and operate consistently with our standards when working on our behalf. By supplying products to us, suppliers are required to certify that they will abide by our standards.

We evaluate and address risks of human trafficking and slavery in our supply chain through a combination of internal and third party verification methods. We require suppliers to consent to audits to evaluate compliance with our standards for trafficking and slavery in our supply chain. We may conduct these audits through third-party audit firms. Audits are unrestricted and may occur with or without advance notice.

We require direct suppliers to certify that materials incorporated into products supplied to us comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. For example, our standards provide that by supplying products to us, suppliers are certifying that they comply with these laws. In some cases, we may require additional written confirmation of these certifications.

We maintain internal accountability regarding slavery and trafficking and procedures for employees failing to meet our standards. Compliance with our standards is part of our employee policies, and failing to comply with the standards may result in disciplinary action or dismissal. Our standards are documented and available for our employees and suppliers. Special attention to our standards is required for employees and management who have direct responsibility for supply chain management. These employees receive training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain.