Transparency in Supply Chains

We are committed to upholding ethical standards across every stage of our supply chain, with a strong focus on preventing forced labor, slavery, and human trafficking. In compliance with regulations such as the California Transparency in Supply Chains Act of 2010, we provide clear disclosure of the measures we take to identify, mitigate, and eliminate these risks. Our overall framework is built around responsible sourcing practices, supplier accountability, and strict adherence to established ethical and legal requirements.

A structured social compliance program forms the foundation of our approach. This program sets out clear expectations that all suppliers must follow, including compliance with applicable labor laws, workplace safety regulations, and ethical business conduct standards. Suppliers are required to maintain these standards throughout their relationship with us. If violations occur, corrective action plans must be implemented, and failure to resolve issues or repeated noncompliance may result in termination of the supplier relationship and removal from approved supplier lists.

Prior to engaging in production, suppliers undergo a review process to ensure they meet both operational and ethical criteria. This includes collecting and evaluating detailed information about their manufacturing facilities, including both domestic and international sites. Risk assessments are conducted using multiple data sources, such as global governance indicators, labor rights and trafficking risk reports, and historical audit findings. This allows for the identification of higher-risk regions or suppliers so that additional scrutiny can be applied before approval is granted.

Ongoing oversight is maintained through a risk-based audit system. Suppliers that are classified as higher risk are subject to more frequent and in-depth evaluations. These audits are conducted by independent third-party organizations and typically include on-site facility inspections, confidential employee interviews, management discussions, and comprehensive reviews of operational and employment documentation. Any noncompliance identified during these audits is addressed through corrective action plans, which are monitored to ensure proper resolution and sustained improvement.

As part of our compliance framework, suppliers are required to formally acknowledge and agree to all applicable legal obligations and internal policy standards. These agreements clearly define expectations regarding ethical sourcing, labor practices, and ongoing compliance responsibilities. This contractual commitment reinforces accountability and ensures that all parties involved in the supply chain operate under consistent ethical guidelines.

Internally, employees involved in sourcing, procurement, and supplier management receive guidance on ethical sourcing standards and are provided with channels to report concerns or potential violations. These reporting mechanisms are designed to support transparency and ensure that issues can be escalated and addressed in a timely manner without fear of retaliation. This helps reinforce a culture of accountability and ethical responsibility throughout the organization.

Training programs are conducted on a regular basis to increase awareness of modern slavery risks and human trafficking concerns within global supply chains. Employees are educated on how to recognize potential warning signs, understand reporting procedures, and apply responsible sourcing principles in their daily responsibilities. This ongoing education ensures that teams remain informed about evolving risks and regulatory expectations.

Through a combination of supplier screening, independent audits, contractual commitments, employee training, and continuous monitoring, we work to promote fair labor practices and reduce risks across our supply chain. These practices are regularly reviewed and updated to align with changing legal requirements and industry standards, ensuring a consistent commitment to ethical sourcing, transparency, and responsible global operations.