California Transparency in Supply Chains Act Disclosures


  1. Verification

We conduct biannual assessments of 30% of our product suppliers to verify that they are not at risk for violating anti-slavery and human trafficking laws. We do not use third-party verifiers. Our own risk-management team spearheads the verification process using an internally developed rubric and multi-part assessment. Our risk-management team is currently unable to verify whether our subcontractors use labor brokers.


  1. Audit

Our internal auditing team annually conducts announced audits of 20% of our direct 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.


  1. Verification

Currently, we do not require 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.


  1. Internal Accountability

In 2013, we developed internal accountability standards and procedures for employees and contractors failing to meet our company standards regarding slavery and trafficking. If and when our company uncovers employee or contractor compliance problems, we provide written notice and a specified period of time to take corrective action.


  1. Training

Our company does not provide employees or contractors with training on human trafficking and slavery.