California Transparency in Supply Chains Act Disclosure

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:

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.