CA SB657: Supply Chain Transparency Act

At our store, we are committed to ensuring ethical working conditions throughout our supply chain. We conduct in-person factory visits and require independent third-party audits to verify that working environments are safe, healthy, and aligned with our standards. In compliance with the California Supply Chain Transparency Act (SB657), we outline the measures we take to prevent human trafficking and slavery in our supply chain.

Verification
We require all direct suppliers to undergo annual compliance audits and quarterly observational audits conducted by an accredited third-party auditing firm. These audits evaluate worker living and working conditions, verify wages and hours, ensure health and safety standards, and confirm that all records and documents are valid and properly maintained.

Our Vendor Code of Conduct (VCOC) is shared with all direct suppliers and must be displayed prominently at each facility. The VCOC is available in English, Spanish, Italian, Chinese Simplified, and Vietnamese. Before starting any business relationship, suppliers complete vendor profiles detailing social responsibility practices, including standard working hours, minimum worker age, disciplinary procedures, and measures against forced or imprisoned labor. This helps us assess potential risks early in the partnership.

Audits
Full audits are conducted annually with a semi-announced 10-day window, performed by accredited third-party auditors. Audits cover labor, wages and hours, health and safety, management systems, and the working environment. Auditors conduct in-person interviews in the local language, review payroll and attendance records, and ensure compliance with legal standards for wages and overtime.

Quarterly unannounced observational audits focus on labor and health and safety practices, providing insights into routine practices at the facility. Corrective Action Plans (CAPs) are issued to address any non-compliance findings, allowing us to collaborate with suppliers to improve systems and procedures. Annual audits include expanded sampling to better represent wages and hours data.

Certification
All direct suppliers are required to comply with our VCOC, which outlines adherence to local and international labor laws, including prohibitions on child labor, forced labor, and discriminatory or abusive practices. We are extending the VCOC to all materials suppliers along the supply chain to ensure awareness and compliance across all parties.

Internal Accountability
Our core values—“The ethical choice is the right choice” and “Everyone can and should make a difference”—guide our internal and supply chain decision-making. We maintain zero tolerance for labor-related non-compliance, and any violations result in immediate termination of the business relationship, regardless of contracts or potential revenue.

All personnel interacting with the supply chain undergo CA SB657 compliance training, which equips them to identify and address non-compliance risks effectively.

Training
Employees and management with direct supply chain responsibilities participate in ongoing training on human trafficking and forced labor. Our Compliance team attends seminars and partners with third-party organizations to stay informed on global labor and human rights issues.

All Product and Supply Chain team members complete CA SB657 compliance training on identifying, mitigating, and reporting risks related to forced labor and human trafficking. This training is mandatory for new hires and ongoing for existing team members to ensure continued awareness and adherence to ethical supply chain practices.