California Supply Chain Act

We are committed to maintaining responsible and transparent sourcing practices and to reducing the risk of forced labor, slavery, and human trafficking within our supply chain. As part of this commitment, we expect the businesses and suppliers involved in producing our products to operate responsibly, follow applicable laws, and maintain working conditions that respect the fundamental rights and dignity of workers.

Our supply chain oversight includes an assessment of risks associated with our direct suppliers. These assessments may be conducted with the assistance of qualified independent third parties that review supplier practices and identify areas where additional attention or corrective measures may be appropriate. Particular consideration is given to risks involving forced labor, involuntary labor, slavery, human trafficking, and other practices that are prohibited by applicable laws and responsible sourcing standards.

Suppliers that manufacture products or provide materials for our business are expected to follow our supplier standards and applicable legal requirements in the countries where they operate. These standards prohibit the use of forced labor in any form and establish expectations regarding ethical business conduct, lawful employment practices, and respect for workers. Suppliers are also expected to ensure that materials incorporated into products are sourced and produced in accordance with relevant laws concerning slavery and human trafficking.

Supplier compliance may be evaluated through independent third-party audits. Depending on the circumstances and the applicable assessment process, these reviews may be scheduled in advance or conducted without prior notice. Audits are intended to evaluate whether suppliers are meeting established standards and complying with applicable local laws. Reviews may consider workplace practices, employment conditions, documentation, and other relevant areas that could indicate potential risks involving forced labor or human trafficking.

Suppliers are also expected to provide appropriate certifications or confirmations regarding their compliance with applicable laws. These certifications may address the supplier’s own operations as well as the materials used in products supplied to us. Suppliers are responsible for maintaining lawful practices in the jurisdictions where they conduct business and for ensuring that relevant materials and production activities do not involve practices prohibited by applicable laws relating to slavery or human trafficking.

When an audit, assessment, certification, or other review identifies a potential violation, appropriate corrective measures may be required. Depending on the nature and seriousness of the issue, a supplier may be asked to develop and implement a corrective action plan within an appropriate period. Such plans are intended to address identified deficiencies, establish improvements, and reduce the possibility that similar issues will occur again. Continued failure to meet required standards or serious violations may result in the termination of the supplier relationship.

Responsible sourcing also depends on employees who oversee or interact with the direct supply chain understanding the standards that apply to their responsibilities. Employees with supply chain-related duties receive training concerning supplier expectations, responsible sourcing requirements, and the importance of identifying and addressing risks associated with slavery and human trafficking. Training also covers the relevant supplier standards and methods for helping reduce these risks throughout the sourcing and procurement process.

Our approach is intended to combine supplier requirements, risk assessment, independent review, certifications, corrective actions, and employee awareness. These measures provide a framework for monitoring direct suppliers and encouraging responsible practices throughout the manufacturing and sourcing process. While supply chains can involve multiple organizations, locations, and production stages, we recognize the importance of maintaining appropriate oversight and responding when potential risks are identified.

We expect our suppliers and business partners to cooperate with reasonable compliance reviews and to provide accurate information concerning their operations. Transparency and accountability are important elements of our supplier relationships, particularly where working conditions and legally protected labor rights are concerned. We may take appropriate action when information or audit findings indicate that a supplier is not meeting required standards.

Through these practices, we seek to strengthen supply chain responsibility, identify potential labor-related risks, and support lawful and ethical sourcing. Our supply chain expectations are intended to promote respect for workers while helping ensure that products and materials are obtained from suppliers that understand and follow applicable requirements concerning forced labor, slavery, and human trafficking.

For questions concerning our responsible sourcing practices or supply chain standards, please contact us at [email protected].