Supply Chain Transparency

Supply Chain

We take seriously federal and international efforts to eliminate all forms of forced labor—whether prison labor, indentured labor, bonded labor, human trafficking or other forms—through the standards set forth in our Code of Conduct, which was originally developed by C1RCA and subsequently adopted by our affiliates, including a section titled “Employment is Voluntary.”

Supply Chain Verification

It is our policy to evaluate potential contract factories before they enter our supply chain to assess their compliance with the standards, including risks of country-related issues such as forced labor, human trafficking and slavery. We use both internal and external third-party audits.

Supplier Audits

We monitor contract factories for compliance with our standards through internal and external audits and independent third-party audits conducted through the Fair Labor Association. We monitor a portion of our contract factory base annually.

Material Certification for Direct Suppliers

We are working to map and understand impacts upstream in our supply chain to develop standards for upstream suppliers to our contract manufacturers.

Compliance Standards

If a contract factory is found to be in violation of the law or our standards, the factory is responsible for improving performance in accordance with an overall action plan. If the factory fails to make progress against that plan, it will be subject to review and sanctions, including possible termination of employment.