CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010
Bigandtall.com (hereinafter referred to as "we", "our" or "Site"), is committed to providing our customers with top-quality merchandise that is manufactured responsibly. That means we expect workers making the products we sell to be treated fairly and with dignity and respect. In addition, we demand adherence to any and all appropriate international and U.S. laws, regulations and industry standards applicable to our Site. We support the intent of the California Transparency in Supply Chains Act of 2010 (the "Act").
We sell both private-label and branded-label products. Our branded-label suppliers are provided with our Code of Conduct, Global Vendor Agreement and Vendor Compliance Guide (collectively the "Agreement") and they are informed that they are required to follow the Agreement. Since 2011, the Act has been incorporated in the Agreement. We ask that you visit the websites of branded-label companies to read about their efforts in complying with the Act.
The suppliers of our private-label products are held to the Agreement which addresses the concerns underlying the Act. Key elements of our practices regarding our private-label products are summarized below:
We examine our product supply chain in an effort to uphold our commitment to work only with suppliers that strictly comply with the Agreement. Each year we require all of our direct suppliers to retain our-approved, independent third-party auditors (the "Auditor") to examine relevant information about each supplier on our behalf. The Auditor evaluates the risks and vulnerability to slavery or human trafficking in the production of our supplier goods. Prior to us conducting business with a new direct supplier, an initial audit is performed by the Auditor and the audit results are submitted to our Senior Director of Vendor Compliance & Quality Assurance for final review and approval.
The Agreement asserts our right to terminate any supplier for cited violations including, but not limited to, slave labor, human trafficking or safety. In 2014, announced audits were conducted at all 30 private-label factories with which we and our affiliates do business. The audits were conducted on site and consisted of the following components: facility tour, document review, confidential worker interviews, and an opening and closing meeting with the facility's key management. We require all suppliers to provide the Auditor with unrestricted access to the production facility and applicable records. After the audit, any violations of our Agreement are documented, and a detailed corrective action plan is required. Regular follow-up visits are also conducted to ensure efforts are made to correct any violations. Ties were severed with one supplier in 2014 due to its uncorrected unsatisfactory audit.
Our private-label suppliers are required to comply with our Agreement and Customs-Trade Partnership Against Terrorism (C-TPAT) standards to ensure the merchandise does not violate the laws regarding slavery and human trafficking of the country or countries in which each supplier transacts business.
The following language is incorporated into the Global Vendor Agreement:
- "The Merchandise is manufactured, assembled, imported, sold, shipped, packaged, labeled and marketed in accordance with all applicable international (in the countries in which the parties are doing business), U.S. federal, state and local laws, ordinances, executive orders and regulations and industry standards including, without limitation, laws, regulations, executive orders and standards applicable to wages, work hours, work place safety, protection of the environment, and the prohibition of discrimination based on the basis of race, color, national origin, gender, religion, disability, sexual orientation or political opinion. Vendor further represents and warrants that convict labor, child labor, forced labor and/or indentured labor under penal sanctions was not employed, in whole or in part, in any stage of the production, manufacture, assembly of the Merchandise or any material or component thereof."
IV. Internal Accountability
Our Chief Sourcing Officer and the Senior Director of Vendor Compliance & Quality Assurance have developed and maintain internal accountability which consists of candid communications with the auditors, vendors, suppliers and agent compliance teams. Our private-label product factories' standards are monitored by the Auditors with direct reporting to us. The Auditor provides us with an Audit Findings Report (the "Audit Report") within five (5) business days of the completion of the audit. The Audit Report provides detailed information for us to understand the context of any non-compliance findings, including the severity and frequency of the infraction. We review each finding with the Auditor and approve the recommended corrective action steps and timeframe. We assert our right to terminate any supplier for cited violations including, but not limited to, slave labor, human trafficking or safety.
Our Chief Sourcing Officer and the Senior Director of Vendor Compliance & Quality Assurance provide routine training on all Agreement requirements to our associates who work in sourcing and/or production and who visit suppliers as part of their job responsibilities. The associates are made aware of the indicators of slave labor and human trafficking, and are required to report any potential issues for further investigation. We strive to keep the appropriate personnel knowledgeable about, and attentive to, social compliance concerns such as human trafficking and slavery.