We are committed to conducting business fairly, ethically, and in accordance with all applicable laws. We require our suppliers to comply with applicable laws related to forced labor and human trafficking, as well as child labor, working hours, harassment, abuse, discrimination, product safety and factory security, in or as part of our supply chain.
Our Business And Supply Chains
We launch, acquire, develop and operate third-party and direct-to-consumer brands through e-commerce and brick and mortar stores.
This wide range of businesses necessarily has supply chains that are highly varied in terms of types of supply and their locations, as well as the potential risks associated with possible labor-related abuses. We therefore focus our efforts on preventing abuses in such supply chains according to the differing levels of risk.
Our Relevant Practices And Policies
Our manufacturing due diligence is performed through our Upstream Supply Chain team. The Upstream Supply Chain team utilizes third party providers to perform inspections. Any indication of red flags based on the International Labour Organization’s eleven indicators is recorded and brought to the attention of the Global Compliance team for review and further testing. We also require our suppliers to adhere to Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307).
All potential new suppliers are screened against U.S. and NATO government watch lists. Screening utilities are used for ongoing red list monitoring and web-based searches are done for new articles or government issued alerts that include indicators of forced labor. All of our suppliers and manufacturers are provided with a copy of our Code of Ethics and the terms of our agreements (including purchase orders), which mandates that our suppliers and manufacturers must comply with applicable law and industry standards. Any violation of our Code of Ethics could lead to the termination of our relationship with the applicable supplier.
Audits
Our Code of Ethics permits us (or third party auditors we engage) to verify our suppliers and manufacturer compliance with any aspect of our Code of Ethics at any time. We engage leading providers of supply chain compliance solutions that are expected to understand local laws, rules and regulations in each applicable jurisdiction and industry standards. Audits may be conducted on site and may involve discussions or interviews with workers and managers as well as a physical inspection.
Violations of the Code of Ethics are required to be documented and each supplier is expected to prepare and implement a detailed corrective action plan in order to maintain its relationship with us. Unannounced follow-up visits also may be conducted to ensure that violations are addressed.
Training
We offer training to employees and management responsible for supply chain management to build understanding and capacity to identify and address slavery or human trafficking, as well as other social responsibility issues.
In addition, as part of our induction program, each employee is trained in our Code of Ethics and our requirements with respect to compliance with laws and behavior in the workplace.
Management Approval
This statement was approved by our Management, which will review and update it annually.