CA SB 657

Marc Jacobs International, LLC and its affiliated companies (collectively, "MJI”) are committed to conducting business in a lawful, ethical and responsible manner. We expect our vendors to respect and adhere to the same business philosophy in the operation of their businesses. California law requires companies to disclose their efforts to address the concerns regarding slavery and human trafficking raised by the California Transparency in Supply Chain Act of 2010 (the "Act”). MJI has a Vendor Code of Conduct which is based on principles of ethical business practices and recognizing the dignity of others, and specifically prohibits the use of involuntary or forced labor, human trafficking, child labor, and harassment and abuse. MJI shares and expects its direct product suppliers (including their designated manufacturing facilities and third parties involved with the manufacturing process) and license partners to adhere to and to implement MJI’s Vendor Code of Conduct (including Supplemental Guidelines) as well as MJI’s Employee Code of Conduct. MJI’s ongoing internal risk assessment of its supply chain is aimed at understanding the potential challenges in a global supply chain. We rely on and analyze information gathered from external resources, updates from expert organizations, and companies dedicated to social compliance issues. MJI engages external third party compliance auditing firms to perform announced, semi-announced and unannounced assessments of a selection of MJI’s direct product vendors each year to evaluate compliance with MJI’s Vendor Code of Conduct and Supplemental Guidelines. Vendors are required to address any non-compliance issue identified during an audit or reaudit. Failure to address and correct violations of the Vendor Code of Conduct can result in a reevaluation of our business relationship with such vendor, up to and including termination of the business relationship. However, continuous improvement is a tenet of our compliance program and MJI examines and develops the best possible strategy to resolve non-compliance issues. MJI requires its direct product vendors to complete a Vendor Compliance Agreement which requires, among other things, an agreement to acknowledge and abide by our Vendor Code of Conduct and Supplemental Guidelines and to certify that they have discussed such and obtained from their suppliers and subcontractors written assurances to also commit to these principles. MJI maintains internal accountability standards and procedures for employees regarding MJI’s commitment to the principles set forth in the Vendor Code of Conduct. Additionally, MJI maintains confidential channels for employees to escalate or anonymously report any concerns. MJI provides training to its employees and management who have direct responsibility for supply chain management with the aim of raising awareness regarding the risks of human trafficking and slavery in supply chains, identifying potential risks, and addressing those risks when human trafficking and slavery are suspected.
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