CA Transparency Act

Our company is committed to maintaining responsible business practices based on integrity, transparency, respect, and fair treatment throughout every stage of its operations. These principles extend across the entire supply chain, covering the sourcing of materials, manufacturing activities, packaging, transportation, and delivery. We expect suppliers, contractors, manufacturers, logistics providers, and other business partners to maintain working environments that respect human rights and comply with applicable labor requirements. Employment must be voluntary, working conditions should be safe, and individuals must be treated fairly regardless of their position or role. Our internal standards are designed to reflect applicable laws, internationally recognized labor principles, and measures intended to prevent forced labor, human trafficking, discrimination, and other abusive practices.

Responsible supply chain management requires more than written policies. For this reason, we maintain processes intended to identify potential risks, evaluate business partners, monitor ongoing performance, and encourage corrective improvements when concerns arise. These processes may include supplier screening, documentation reviews, internal assessments, independent audits, workplace inspections, employee training, and periodic compliance evaluations. By combining several monitoring methods, we can obtain a broader understanding of working conditions and business practices across different levels of the supply network.

Before entering into a business relationship, prospective suppliers and service providers may undergo a detailed evaluation. This assessment can cover workplace conditions, employment practices, health and safety procedures, compensation arrangements, working hours, management systems, and compliance with relevant legal requirements. Suppliers are expected to maintain appropriate records that demonstrate responsible operations and allow important information to be reviewed when necessary. Approval of a business partner does not end the monitoring process, as existing suppliers may be reviewed periodically to confirm that expected standards continue to be maintained.

Oversight can extend beyond direct manufacturing partners to include subcontractors and other organizations involved in producing or handling merchandise. This broader approach helps reduce the possibility that unacceptable practices may occur at a lower level of the supply chain without appropriate attention. Where business partners rely on additional facilities or labor providers, they may be expected to maintain comparable standards and provide sufficient information regarding those relationships. Reviews may be conducted at different intervals depending on operational circumstances, identified risks, previous findings, and applicable requirements.

Workplace assessments may examine a variety of conditions that influence employee welfare. Areas of consideration can include wage practices, working schedules, occupational safety, emergency procedures, accommodation conditions where relevant, recruitment methods, and workplace conduct. Particular attention may be given to indicators of coercion, deceptive recruitment, withholding of personal documents, unlawful deductions, debt-related pressure, or other circumstances that could undermine a person’s freedom to work voluntarily. Policies concerning discrimination, harassment, freedom of association, and respectful treatment may also form part of the review process.

When an assessment identifies a concern, the affected business partner may be required to develop and implement a corrective action plan. Such plans can identify the specific issue, establish appropriate measures for addressing it, and set a reasonable timeframe for completion. Follow-up assessments may then be used to determine whether the proposed improvements have been effectively implemented. Minor issues may require documented remediation and continued monitoring, while serious or repeated violations may result in suspension or termination of the business relationship.

Compliance with applicable laws is an essential condition of working with our organization. Suppliers and contractors are expected to observe relevant labor regulations, employment requirements, trade rules, human rights protections, and laws addressing forced labor and trafficking. They should also maintain accurate operational records and provide truthful information during compliance reviews. Significant violations, falsified documentation, refusal to cooperate with required assessments, or serious misconduct may lead to additional corrective measures or termination of the applicable agreement.

Ethical standards also apply within our own organization. Employees, contractors, managers, and other participants in business activities are expected to follow established policies and behave responsibly when dealing with colleagues, suppliers, customers, and other stakeholders. Confirmed violations may result in appropriate disciplinary action, which can include additional training, formal warnings, suspension, or termination depending on the nature and seriousness of the conduct.

Employees and business partners are encouraged to raise concerns when they become aware of possible misconduct. Reporting channels may be provided to allow individuals to communicate concerns confidentially and, where appropriate, anonymously. Protection against retaliation is an important part of this process because individuals should be able to report suspected violations without fear of unfair treatment for making a good-faith report. Concerns can be reviewed through appropriate internal procedures so that relevant facts can be considered and suitable action can be determined.

Training and education support the long-term effectiveness of these standards. Personnel involved in purchasing, sourcing, supplier management, legal matters, compliance, and related functions may receive regular instruction regarding responsible labor practices and emerging supply chain risks. Business partners may also be provided with guidance intended to strengthen their understanding of workplace expectations and applicable requirements. Ongoing education helps participants recognize potential problems earlier and respond to them in a consistent manner.

Our compliance framework is reviewed as laws, regulations, industry expectations, and operational conditions develop. Policies may be updated when new risks emerge or when additional safeguards become appropriate. Through continuous monitoring, supplier engagement, employee education, responsible sourcing, and transparent reporting procedures, we seek to maintain a supply network that supports lawful operations, safe workplaces, human dignity, and accountable business relationships.