CA Supply Chain Transparency

Disclosure

The California Transparency in Supply Chains Act of 2010 requires companies manufacturing or selling products in the State of California to disclose what efforts they are taking to eradicate slavery, forced labor, and human trafficking from their direct supply chains for tangible goods they offer for sale. The law’s underlying purpose is to educate consumers so that they can make informed decisions and purchase goods from companies that responsibly manage their supply chain.

Slavery, forced labor, and human trafficking can take many forms, including child labor. Just Born has a zero-tolerance policy for any forced or compulsory labor, including slavery and human trafficking, used in the manufacture of all products that it sells. Just Born’s efforts to eradicate slavery, forced labor, and human trafficking from its supply chain include the following:

1. Verification: Just Born self-verifies its product supply chains to evaluate and address risks of human trafficking and slavery. Just Born has not found it necessary for these verifications to be conducted by a third party because it is confident that human trafficking and slavery is not a part of its supply chain.
2. Auditing: Just Born currently conducts periodic onsite audits of suppliers to evaluate supplier compliance with its standards regarding human trafficking and slavery in its supply chain. Audits conducted by Just Born are typically pre-coordinated audits, but in some cases audits may be unannounced.
3. Certification: Just Born standard purchase terms and conditions requires its direct suppliers to certify that materials, goods, and services they furnished to Just Born comply with federal, state, and local laws, which include laws regarding slavery and human trafficking in the country or countries in which they are doing business. Suppliers must certify that they are not consciously engaging in practices such as:
   • Child labor
   • Harassment and/or abuse
   • Forced labor/Human trafficking (in all its forms)
   • Health and Safety conditions posing immediate risk to life or limb
4. Internal Accountability: Just Born maintains internal accountability standards and procedures for employees or contractors failing to meet its standards regarding slavery and trafficking. Our company requires key suppliers to agree and sign a Vendor Guidelines and Compliance Agreement as part of entering into a business transaction. Non-compliance with our agreement will result in termination of the business relationship.
5. Training: While Just Born does not currently provide training on human trafficking and slavery to its employees and management who have direct responsibility for supply chain management, Just Born has and will continue to review the necessity of providing training concerning these issues, particularly with respect to mitigating risks within its supply chains of products.