As of January 1, 2012, California’s Civil Code section 1714.43 (California Transparency in Supply Chains Act of 2010) requires manufacturers and retailers to provide website information concerning their efforts to address the issues of forced labor, slavery, and human trafficking within the supply chain. The purpose is to allow consumers to make more informed decisions about the products they buy and the companies they support. To this end, the California law directs Vintage Brand to inform the public how it has addressed the issues in italics, below.Background: Vintage Brand’s Approach to Social Compliance and Labor Standards
Vintage Brand believes that providing our customers and partners with a high quality product, innovative customization, and a pleasant shopping experience is only meaningful when produced with ethical labor practices and codes of conduct for international labor and human rights standards. Our suppliers and vendors are required to follow best practices in terms of child labor, harassment policies, freedom of association, health and safety standards, working hours, and compensation for overtime as well as all applicable laws, regulations, and treaties. Vintage Brand contracts all product fulfillment to a facility in the United States, located in Louisville, KY. We have implemented a robust set of standards for our company-owned facilities and suppliers for over 15 years. Vintage Brand realizes that forced labor and human trafficking can occur in many forms – such as child labor, workplace harassment, workplace abuse, and workplace discrimination. Therefore, our processes (described above and below) were created in an effort to eradicate such unethical practices.
We are also a Category C member of the Fair Labor Association (FLA), an internationally recognized non-governmental organization (NGO) whose goal is to advance labor rights globally and help industry appropriately address a range of complex issues – including the eradication of forced and slave labor across the supply chain. Our work with the FLA, and other global NGOs and organizations, has proven valuable in our efforts to ensure that our suppliers are compliant with both our own standards and relevant international norms.CA Transparency in Supply Chains Act: Statements
(1) Verification of product supply chains to evaluate and address risks of human trafficking and slavery.
Vintage Brand does not source any products on its own, but purchases all its products from U.S. companies, both manufacturers and distributors, who maintain the highest ethical standards for their supply chains, which include both U.S. and international manufacturers. Vintage Brand seeks to source products from U.S. Companies who regularly perform geographic evaluations of their supply chains to evaluate the risk of noncompliance in slavery, human trafficking and other human rights and labor issues. Vintage Brand’s analysis of these issues is not conducted by a third party.
(2) Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.
Vintage Brand seeks to source products from U.S. companies who work aggressively to audit suppliers to exclude labor and human rights abuses from its supply chain. The intensity and frequency of these audits vary based on these companies’ geographical risk evaluations and also on the historical performance of a given factory in prior audits. Vintage Brand also seeks to source its products from U.S. companies whose international facilities and finished goods contractors are certified by the Worldwide Responsible Accredited Production program (WRAP). The WRAP process is rigorous, and is described more fully at www.wrapcompliance.org.
(3) Certification by direct suppliers that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Vintage Brand’s finished-goods suppliers are required to sign a comprehensive agreement which, among other things, requires them to comply with all applicable laws, including those regarding slavery and human trafficking. Our suppliers of component materials and parts are also required via our purchase order process to comply with Vintage Brand’s policies and all applicable laws, including those regarding slavery and human trafficking.
(4) Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Vintage Brand maintains internal accountability standards and procedures applicable to suppliers who may fail to meet our companies’ standards. We are a current member in good-standing with the Fair Labor Association (“FLA.”) As such, we have an FLA committee within our organization that meets regularly to discuss FLA policies and compliance. We strive to source our products only from U.S. companies that have rigorous compliance audits of foreign manufacturers, a formal corrective action plan to correct problems found, and a zero-tolerance on issues such as forced/prison labor, slavery, human trafficking, child labor, physical/sexual abuse, and bribery of an auditor.
(5) Training of company employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
We regularly conduct training on our standards, and we strive to purchase products from U.S. companies who believe a thorough training of the requirements of these standards is critical to mitigating risks associated with issues of forced labor, slavery, human trafficking and child labor.