The California Transparency in Supply Chains Act of 2010 seeks the elimination of slavery and human trafficking from product supply chains and requires many retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.
We embrace this goal. While we believe the risk of slavery or human trafficking in our supply chain is low, we nonetheless have a variety of mechanisms in place to assess and reduce the risks.
We seek to build relationships with our suppliers based on mutual benefit, trust, performance, and a joint commitment to continuous improvement. We require our suppliers to operate ethically and to comply with all contract terms, laws, and regulations.
We employ various methods for assessing the risk of slavery and human trafficking in our supply chain, including routine visits to facilities by employees and assessments by third-parties. Many of our supplier's facilities are assessed by the Worldwide Responsible Accredited Production (WRAP) program, which is an independent, non-profit organization dedicated to the certification of lawful, humane, and ethical manufacturing throughout the world. We also conduct periodic announced and unannounced audits and visits of suppliers' facilities and requires suppliers, when possible, to be certified by an independent organization.
If needed, we work with our suppliers to develop a corrective action plan to address gaps or vulnerabilities. A supplier's failure to comply with our expectations regarding slavery and human trafficking will result in termination of the supplier relationship. We place a responsibility on our employees as well. Our employees are required to report anything they observe or discover that indicates our standards are not being met. Every employee is expected to be an active proponent of our principles. Employees who fail to comply with our expectations are subject to disciplinary action, up to and including termination of employment. To minimize the risk of this occurring, our long-term goals include educating our employees involved in supply chain management as to the risks of slavery and human trafficking.