Supply Chain Statement
·¬ÇÑÊÓƵAPP ("·¬ÇÑÊÓƵAPP") is committed to responsible sourcing and, specifically the elimination of human trafficking and slavery in our supply chain, if any.
Verification: ·¬ÇÑÊÓƵAPP currently requests that its direct suppliers for ·¬ÇÑÊÓƵAPP's tangible goods offered for sale ("Suppliers") complete an Onboarding Package as part of our initial intake process, and certify in all purchase orders that the Supplier acknowledges and agrees that "no applicable governmental laws, rules, or regulations have been violated in the manufacture or sale or shipment" of the items purchased in such purchase order. Our standard manufacturing agreement also requires Suppliers to represent that they have read and agree to act in a manner consistent with ·¬ÇÑÊÓƵAPP’s Code of Business Conduct and Ethics which expressly states that "·¬ÇÑÊÓƵAPP 1) does not use or condone the use of slave labor or human trafficking; 2) denounces any degrading treatment of individuals or unsafe working conditions; and 3) supports [·¬ÇÑÊÓƵAPP's] products being free of conflict minerals."
·¬ÇÑÊÓƵAPP is currently in the process of updating our Onboarding Package to require current and prospective Suppliers to self-certify regarding the eradication of human trafficking and slavery.
·¬ÇÑÊÓƵAPP anticipates that its Supplier Standards and verifications will reserve the right for ·¬ÇÑÊÓƵAPP to engage in its own verification process of Supplier representations or by engaging a third party to conduct such verifications.
Audits: ·¬ÇÑÊÓƵAPP's standard manufacturing agreement currently reserves ·¬ÇÑÊÓƵAPP's right to conduct onsite audits of its prospective and existing Suppliers' manufacturing facilities. ·¬ÇÑÊÓƵAPP conducts such audits of its top 20 Suppliers by sales volume through its own personnel on an announced basis.
·¬ÇÑÊÓƵAPP is in the process of revising its standard Purchase Order Terms & Conditions to expressly reserve the right to conduct onsite audits of its prospective and existing Suppliers to evaluate the Supplier's compliance with all applicable laws, regulations, rules, practices and procedures, as well as its Onboarding Package representations and anticipated Supplier verifications of ·¬ÇÑÊÓƵAPP's Supplier Standards. ·¬ÇÑÊÓƵAPP envisions that it may conduct such audits through its own personnel or an independent third-party auditor, on an announced or unannounced basis.
Materials: ·¬ÇÑÊÓƵAPP currently requests through its standard manufacturing agreement with Suppliers that its Suppliers undertake and agree to act consistently with the ·¬ÇÑÊÓƵAPP Code of Business Conduct and Ethics, which states that "·¬ÇÑÊÓƵAPP … supports [·¬ÇÑÊÓƵAPP's] products being free of conflict minerals."
·¬ÇÑÊÓƵAPP is also in the process of requiring that Suppliers certify in the Onboarding Package and verifications to ·¬ÇÑÊÓƵAPP’s Supplier Standards that materials incorporated into ·¬ÇÑÊÓƵAPP's products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Accountability Standards: ·¬ÇÑÊÓƵAPP's Code of Business Conduct and Ethics currently has a written policy setting out its accountability standards with respect to Forced Labor and Anti-Trafficking, and provides that any employee who violates the Code of Business Conduct and Ethics "will be subject to appropriate discipline, which may include dismissal."
Training: ·¬ÇÑÊÓƵAPP has completed training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks within the supply chain.