California Transparency in Supply Chains Act and ILO Compliance

 

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.  In its effort to supply products free from the taint of slavery and human trafficking, Avenue Stores, LLC complies with the provisions of the International Labor Organization (“ILO”), and adheres to the following procedures to manage its supply chain operations:

 

1. Verification.  Prior to and during any contractual relations involving the procurement of goods or services, representatives from Avenue Stores, LLC, accompanied by outside observers as the case may be, reserve the right to access the factory’s administrative documents and personnel, and may visit sites used for producing, packaging and transporting the products or services in order to evaluate the conditions and confirm the vendor’s full compliance with the CoC.

 

2. Audits.  As described in Section 1 above, Avenue Stores, LLC, whether in conjunction with outside observers or not, reserves the right to access the factory’s administrative documents and personnel, and may visit sites used for producing, packaging and transporting the products or services in order to evaluate the conditions and confirm the vendor’s full compliance with the CoC.

 

3. Certification.  Avenue Stores, LLC requires all of its suppliers to certify their compliance with applicable laws and regulations of the United States and those of the respective country of manufacture or exportation.  A contractual relationship is contingent upon receipt of the vendor’s certification signifying its agreement with Avenue Stores, LLC Code of Conduct (CoC), which incorporates the principles of the ILO as well as the procedures identified in this disclosure.  The CoC includes provisions regarding the use of child labor, prison or forced labor, discrimination, disciplinary practices, freedom of association, working hours & overtime wages & benefits, environment, and health & safety.  Certifications are required at least every two years.

 

4. Accountability.  For all parties contracting with Avenue Stores, LLC, compliance with the CoC represents, in addition to and notwithstanding any contractual clause, a substantial condition of commercial relationship. In case of failure to comply with the CoC, Avenue Stores, LLC will determine in its sole and exclusive discretion what corrective measures should be taken, including termination of the contractual relationship in cases where remediation of the noncompliance is not feasible or cannot be accomplished within a timeframe reasonably acceptable to Avenue Stores, LLC.

 

5. Training.  Avenue Stores, LLC provides training to individuals who manage procurement and supply chain activities to ensure they understand our and our vendors’ compliance obligations under the CoC, ILO and the Act.