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    CA TRANSPARENCY

    EASY SPIRIT, LLC.

     

    Statement for the California Transparency in Supply Chains Act (SB 657)

     

    Easy Spirit, LLC. (the “Company” or “we”) is committed to legal compliance and ethical

    business practices in all of our operations worldwide. We choose suppliers and contractors who

    we believe share that commitment.

     

    We take the risks of slavery and human trafficking in our supply chain very seriously. Like many

    companies manufacturing or selling products in California, we are required to comply with the

    California Transparency in Supply Chains Act of 2010 (California Senate Bill 657) beginning in

    2012. That law was designed to increase the amount of information available to consumers about

    the efforts of manufacturers and retailers to eliminate the risk of modern day slavery, forced labor,

    human trafficking and similar human rights violations (“slavery and human trafficking”) from

    their supply chain. Accordingly, below are some examples of how we are working to eliminate

    that risk from our supply chain.

     

    1. RISK ASSESSMENT. The Company internally assesses the risk of slavery and human

    trafficking with respect to the supply chain for all of its products. To judge which of its sourcing

    countries presents the highest risk levels, the Company utilizes several resources, including the

    U.S. State Department’s annual Trafficking in Persons Report’s country rankings, the United

    Nations Office on Drugs and Crime’s Global Report on Trafficking in Persons, the DirectorGeneral

    of the International Labour Organization’s reports on forced labor, and the U.S.

    Department of Labor’s List of Goods Produced by Child Labor or Forced Labor. The Company

    continuously assesses its risk as these resources are updated and as new, credible resources

    become available.

     

    2. AUDITS. The Company conducts audits of its direct suppliers to evaluate compliance with the

    Company’s Standards for Contractors and Suppliers, which include standards for slavery and

    human trafficking in the supply chain. To determine factory selection and timing for audits we

    look at several criteria, including factory location (country), size, workforce composition and past

    compliance performance, if available, to determine facility risk and audit priority. In addition to

    our internal staff, we retain a number of recognized, unaffiliated third party workplace compliance

    audit firms to conduct both announced and unannounced factory audits on our behalf.

    The Company utilizes a scorecard system to assign risk levels to suppliers objectively based on

    audit results. The scorecard concept is a data-driven process, with the underlying premises that

    not all violations should be treated equally and that some findings are more serious and not as

    easily corrected as others. By comparing audit results, the scorecard system allows the Company

    to evaluate and determine where monitoring is needed most. Over time, audit scores reflect the

    compliance status of a factory, making it a useful tool for internal production divisions to

    benchmark their factories, vendors and agents when making sourcing decisions. The Company

    also supports ongoing supplier improvements through training and technical assistance.

     

    3. SUPPLIER CERTIFICATION. The Company requires that all of its suppliers comply with

    applicable laws within their country of business regarding slavery and human trafficking. Since

    1996, the Company has required all of its contractors and suppliers to adhere to its Standards for

    Contractors and Suppliers, which, among other things, prohibits child labor and any form of

    forced, compulsory, bonded, indentured or prison labor and requires compliance with applicable

    laws and regulations regarding health and safety in working conditions. In addition, as part of the

    Company’s purchase order and commercial invoice processes, factories are required to certify

    compliance with the Company’s Standards concerning elimination of the risk of slavery and

    human trafficking practices in their supply chains.

     

    4. ACCOUNTABILITY STANDARDS AND PROCEDURES. All Company employees and

    agents with production, sourcing or quality control responsibilities, as well as internal buying

    offices and trading companies doing business with the Company, are provided with copies of the

    Company’s compliance program policies and procedures related to the enforcement of its

    Standards for Contractors and Suppliers. These policies and procedures, which are outlined in our

    Corporate Compliance Operations Manual, include issuance of zero tolerance notifications for

    violations of the Company’s prohibition on use of child or forced labor and implementation of

    corrective action plans. In the case of non-compliance, the Company examines the specific

    situation and develops an appropriate strategy for resolution.

     

    5. TRAINING. The Company conducts internal training of its managers and employees with

    direct responsibility for supply chain management that specifically raises awareness of slavery and

    human trafficking and focuses on mitigating the risks within our supply chain. In addition, the

    Company’s internal corporate compliance employees, as well as third party monitors contracted to

    audit facilities in the Company’s supply chain, have participated in training jointly developed and

    delivered by the United Nations Global Initiative to Fight Human Trafficking (“UN.GIFT”) and the

    International Labor Organization (“ILO”). That training helps internal and external monitors to

    thoroughly monitor the risk of forced labor in the Company’s supply chain and to develop and

    deliver training programs for agents, vendors and other supply chain partners on the issue,

    including how to identify and mitigate forced labor and trafficking risks in their recruitment

    processes.

     

    The Company also conducts training programs targeted to suppliers on topics that support

    awareness of the Company’s Standards for Contractors and Suppliers to ensure the appropriate

    participants in supply chain management are knowledgeable concerning the Company’s

    requirements for suppliers. The Company encourages its agents, vendors and suppliers to

    participate in seminars and training programs on social compliance issues (including the issues of

    slavery and human trafficking) to further raise awareness of the issues and mitigate the risks

    within the Company’s supply chain.

     

     

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