California Transparency Act
On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. Under the law, large manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s underlying purpose is to educate consumers, so they can make informed decisions and purchase goods from companies that responsibly manage their supply chains.
XXXXXX, LCC (“Trophy Yoga” or “we”) fully supports California’s efforts to protect human rights and enforce ethical labor practices under the California Transparency in Supply Chains Act of 2010 (SB 657).
Human trafficking, also known as modern-day slavery, is a form of slavery that can include forced labor, bonded labor, sex trafficking and domestic servitude. The International Labour Organization (ILO) estimates indicate that an estimated 24.9 million people are subject to forced labor globally. Modern slavery takes many different forms that can be hard to see. Even if an organization supports anti-slavery practices, the lack of a well-regulated supply chain can leave it open to the use of forced labor. This is why we see transparency, traceability of our supply chains and accountability as the only way of doing business. Trophy Yoga believes modern slavery and human trafficking are egregious violations of human rights and we are deeply committed to doing our due diligence to minimize, detect and remediate forced labor and human trafficking within our supply chain.
At Trophy Yoga, we hold ourselves and our vendors accountable to high ethical standards wherever we do business. Trophy Yoga works diligently to ensure Trophy Yoga’s products are produced ethically by our suppliers and in accordance with high standards, which our suppliers are subject to as a condition of doing business with Trophy Yoga.
We expect our suppliers to adopt and maintain terms of employment for their employees that comply with local law and the requirements of our Supplier Code of Conduct. The following are actions we take to prevent the use of modern-day slavery and forced labor in our supply chains:
EVALUATION AND VERIFICATION OF SUPPLY CHAIN
We require that as a condition of doing business with us, suppliers:
- Agree not to engage in any form of human trafficking or slavery. We describe examples of good management practices for evaluating and addressing risks of human trafficking in their own supply chain, including not using forced or involuntary labor of any type (e.g., forced, bonded, indentured, involuntary prison labor) or illegal child labor.
- At a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates and other elements of compensation, and provide legally mandated benefits.
- Treat all employees with respect and will not use corporal punishment, threats of violence or other forms of physical coercion or harassment. Supplier should have a policy that prohibits inappropriate conduct and a process for employees to report such conduct for supplier’s investigation and resolution.
COMPLIANCE ASSESSMENTS AND AUDITS
Trophy Yoga reserves the right to verify a supplier’s compliance with the Supplier Code through audits or on-site inspections, including interviews of the supplier’s employees in order to evaluate compliance with our standards for trafficking and slavery in supply chains and other Trophy Yoga standards. In order to ensure continued compliance with our Supplier Code of Conduct, all Tier 1 suppliers and their subcontractors must agree to semi-announced audits (14 day window of when the audit can occur) on an annual basis (at a minimum) by our independent and accredited third-party monitoring firms. Suppliers must grant full access (all facilities, employee records and employees for confidential interviews), maintain accurate documentation necessary for demonstrating compliance with our standards and be fully transparent when submitting to assessments.
Trophy Yoga requires our suppliers to strive to meet our requirements as well as demonstrating a commitment to our core values of transparency, open and ongoing communication, accountability and continuous improvement. Suppliers are expected to remediate any noncompliance issues in a timely manner which is reasonable and defined. Trophy Yoga works with suppliers to try and find the root cause of the issue and to develop necessary management, systems within the factory, to ensure ongoing compliance and continuous improvement.
CERTIFICATION OF SUPPLIERS AND MATERIALS
We are committed to achieving transparency and traceability of our supply chain. We currently require any facility involved in the manufacturing of Trophy Yoga product to be disclosed regardless of the facility level and production process, this includes but is not limited to mills, dye houses and printers, yarn spinners and fiber producers. If the Supplier continues to be non-compliant with our standards or corrective action plans, that Supplier may be removed from our supply chain.
INTERNAL ACCOUNTABILITY STANDARDS
Trophy Yoga is committed to the highest standards of conduct throughout our supply chain. On a regular basis, we review and update our policies and procedures to ensure that our high standards are upheld and to guard against the mistreatment of anyone in our supply chain.
Employees in our Supply Chain, Sustainability and Procurement functions that interact with our supply chain receive training in recognizing and preventing and forced labor which includes but is not limited to understanding the red flags of forced labor, awareness of the risk factors related to forced labor and the steps to take to prevent forced labor and meet legal requirements.
VICTIM SUPPORT
Everyone has the potential to discover a human trafficking situation. If you think that you might have known or identified a victim of forced labor or human trafficking, please visit https://www.state.gov/j/tip/id/index.htm or call 1-888-373-7888 for information on how to help and to report a tip.
