The California Transparency in Supply
Chains Act of 2010 (SB 657) (the “Act”) requires certain manufacturers
and retailers doing business in the State of California to disclose
information regarding their efforts to eradicate slavery and human
trafficking from their direct supply chains. Polartec, LLC (Polartec)
adheres to the following procedures:
- Verification: In order to verify
compliance with the terms set forth in the Polartec purchase order,
Polartec reserves the right to access a supplier’s factories and other
sites used for producing, packaging and transporting the purchased
products and/or services.
- Audits: As described in Section 1 above,
Polartec reserves the right to access a supplier’s site, and may also
audit the supplier’s records that pertain to purchases made by Polartec.
- Certification: Polartec does not
currently require certifications from its suppliers. However, Polartec’s
purchase order terms require the supplier to represent and warrant to
Polartec that the supplier’s production, manufacture, packaging, sale,
distribution, installation and pricing of any and all products are in
full compliance with applicable laws, regulations, rules and ordinances
in the location where the products are made, as well as in jurisdictions
through which the products pass and are eventually delivered to
Polartec or its agents. These representations and warranties
specifically cite and require compliance with labor laws, and expressly
prohibit (a) the use of child labor (as defined under applicable law);
(b) forced or compulsory labor; (c) physical abuse of workers; and/or
(d) disregard or failure to comply with applicable rules and laws
governing wages, benefits, working hours, working conditions and payment
for overtime.
- Accountability: Polartec reserves the
right to terminate the relationship with a supplier if the supplier
fails to comply with the terms of the purchase order, including for a
breach of a representation or warranty contained therein.
- Training: Polartec provides training to
individuals who manage procurement and supply chain activities to ensure
they understand the terms found in the Polartec purchase orders. In
addition, all employees are provided with a copy of the Polartec
internal code of conduct.