California Transparency in Supply Chains Act Disclosure

Transparency in Supply Chains Act which became effective as of January 1, 2012, requires companies doing business in California and exceeding certain volume thresholds, to disclose their efforts to eradicate slavery and human trafficking in its direct supply chain for tangible goods offered for sale.

The efforts that we have undertaken to verify the absence of forced labor and child labor in our supply chain include the following:

  1. Factory Certification of Compliance to IML Social Compliance Standards - IML requires all of its suppliers to provide us with a written confirmation that it will adhere to IML social compliance standards which include commitment not to employ or utilize forced, prison, bonded, indentured, slave or underage workers and not to engage in any illegal human trafficking activity.

  2. IML Purchase Orders - All IML's Purchase Orders placed to vendors contain a clause stating that vendors represent and warrant that the materials covered by the purchase orders are not manufactured or sold by vendor in violation of any third party rights, including intellectual property rights, and that Vendor and its suppliers (a) comply with all applicable labor laws, pay wages representing the legal minimum wage or the prevailing wage, whichever is greater, and comply with applicable laws and industry standards on working hours and conditions; (b) comply with all applicable child labor laws and employ only workers who meet the legal minimum working age or are at least 15 years of age, whichever is greater, (c) do not use any prison, indentured, bonded, slave or forced labor; and (d) comply with all applicable environmental laws and legislation. Vendor understands that its failure to comply with the foregoing shall constitute a material breach of the agreement and agrees to indemnify Purchaser against any liability by reasons of the foregoing.

  3. Assessing Risk - Factories are audited based on the amount of business with IML and perceived risk based on previous audit findings and internal risk ratings for the country of manufacture, taking guidance from information provided by the U.S. State Department and U.S. Department of Labor on the topics of forced labor and human trafficking.

  4. Accountability To Our Standards - We are aware that suppliers may not fully comply with our Standards at all times, however management must be willing to commit to improving in areas where we have found non compliance. If we see that improvements are being made, we will generally continue to work with the supplier. During the process, if suppliers are not responsive, we will inactivate the supplier code thus restricting future business. However, under no circumstances will IML tolerate doing business with any supplier found to utilize any prison, indentured, bonded, forced, slave or underage labor. Any indication of violation to these requirements will subject supplier to cancellation of open purchase orders and termination of future business.