Compliance

Verification

Moral labor practices within our supply chain are important to us. Though it is not feasible to verify 100% compliance through our supply chain, down to the raw material in all products that we supply, we are deeply committed to the ethical practices of our immediate suppliers. Currently we engage a third-party verifier to audit specific, but not all suppliers with regard to the use of slavery and human trafficking. To the best of our knowledge our current suppliers do not use labor brokers or engage in slavery or human trafficking.

Audits

Our internal auditing team conducts announced audits of our largest suppliers to evaluate their compliance with our anti-slavery and human trafficking company standards. Audits consist of individual and group interviews with supervisors and management, as well as exhaustive facility tours.

Certification

We are currently in the process of requiring our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business, through our purchasing contracts.

Accountability

Non-compliance with our company standards regarding slavery and trafficking may result in termination of relationship or execution of accountability process named in our contracts, which may include execution of a security bond, liquidated damages, return to compliance measures, or other means.

Training

Supply-chain management ethics training is made available to those employees involved in vendor selection and contract negotiation to allow us to improve our ability to recognize problem areas within the supply chains of our products.