Supply Chain Disclosure

The California Transparency in Supply Chains Act requires us to disclose our efforts to eradicate slavery and human trafficking from our direct supply chains. We take seriously the federal and international efforts to end all kinds of forced labour – whether in the form of prison labour, indentured labour, bonded labour, human trafficking or otherwise – through standards set forth in our Code of Conduct, originally established by C1RCA, and subsequently adopted by our affiliated companies, including the section “Employment is Voluntary”.

Supply Chain Verification

Our policy is to evaluate potential contracted factories before they enter our supply chain to assess compliance with standards including country-related risk for issues including forced labour, human trafficking and slavery. We use both internal and external third-party audits.

Supplier Audits

We monitor contracted factories’ adherence to our standards through internal and external audits, as well as independent, third-party audits through the Fair Labour Association. Each year we monitor a subset of our contract factories base.

Direct Suppliers’ Certification of Materials

We are working on mapping and understanding impacts further up the supply chain, to develop standards for upstream suppliers of our contracted manufacturers.

Standards for Compliance

If a contracted factory is found to violate laws or our standards, it is responsible for improving performance against a master action plan. If the factory fails to make progress against that plan, they are subject to review and sanctions, including potential termination.


Employees and management with direct responsibility for supply chain management are provided training on forced labour, including human trafficking and slavery.


For more information on the Code of Conduct and the Employment is Voluntary Code Leadership Standard, please look online.