FAQ - CA Supply Chain Transparency Act

Transparency in Dôen’s Supply Chain
An estimated 21 million people globally -- the majority of whom are women and girls1 -- are forced into labor and subjected to all forms of slavery, including debt bondage, sex trafficking, and human trafficking, in virtually every industry and across all sectors. In 2010, our home state of California passed the California Transparency in Supply Chains Act2 (the “Act”) in order to provide citizens and consumers with information about corporate efforts to eradicate human trafficking and slavery within their product supply chains, both domestically and internationally. The Act requires large companies with annual sales of over $100 million to disclose any and all efforts to prevent and eliminate human trafficking and slavery from their direct supply chain pertaining to five specific areas: verification, audits, certification, internal accountability, and training.

While the Act does not currently apply to Dôen, we strongly believe in accountability and transparency when it comes to maintaining our high ethical standards and brand values. Therefore, we are voluntarily providing details below on our multifaceted strategy to prevent and eliminate human trafficking and slavery from our direct supply chain.

Verification
We are committed to fair labor practices within our supply chain. As part of our efforts to verify our suppliers’ compliance with Dôen’s standards and applicable laws, all suppliers are required to comply with the Dôen Vendor Requirements. Our suppliers must be willing to participate in social compliance audits performed annually by a third party & the results are shared between the supplier & Dôen team. Third party verification is determined by a variety of factors, including reports concerning the suppliers’ human rights record, if available, and adherence with all applicable federal, state, local, and international labor ordinances. The Dôen Vendor Requirements details expectations for suppliers’, contractors’, and subcontractors’ compliance with applicable employment laws and regulations regarding minimum age of employment, slavery, human trafficking, health and safety in the workplace, discrimination, work hours and conditions, rates of pay, and other terms of employment.

Audits
Doen or our third party audit partners conduct social & safety audits on our finished goods facilities to verify our suppliers’ compliance with Doen’s standards. On an annual basis, we perform audits on all of our finished goods supplier facilities that are either announced or unannounced and are conducted by either internally or by an external third party. These audits certify the prohibition of forced, involuntary, or trafficked labor, and also certify that health and safety must be prioritized with a safe, clean, healthy and productive workplace provided for employees above all else. To learn more about our audits https://shopdoen.com/pages/our-impact-update

Certification
As a condition of doing business with Doen, all our vendors, suppliers, contractors, and subcontractors warrant that the products they supply to Doen are manufactured in accordance with all applicable local, state and federal laws. Doen will not do business with a vendor that fails to warrant compliance with all applicable laws and will discontinue doing business with a supplier who fails to live up to that promise as determined by our annual audits. Through our Dôen Vendor Requirements, all of our vendors are notified in writing of Doen’s policy and expectations regarding forced labor.
1 1 International Labour Organization, Forced Labour, Human Trafficking and Slavery, http:// www.ilo.org/global/ topics/forced-labour/lang--en/index.htm (as of Feb. 6, 2015).
2 Cal. Civ. Code, § 1714.43.

Internal Accountability
We communicate our zero tolerance for human trafficking to our suppliers, employees and contractors. If forced labor indicators are found in a supplier’s facility, we will work quickly to implement an appropriate corrective action plan that is verified by a third party auditor. If the corrective action plan is not completed or the issues do not seem conducive to remediation, we will stop working with a facility. Non-compliance with our company standards regarding slavery and trafficking can result in corrective action or termination, depending on the non-compliance found and its severity. While we believe in sustainable remediation, we reserve the right to terminate a business relationship with an employee or contractor if we deem it necessary.

Training
The senior members of our Production & Sourcing teams will complete mandatory training sessions facilitated by an external agency that specializes in education on identifying and preventing Human Trafficking by December 2021, and they will repeat training on an annual basis.