California Code

CALIFORNIA SB 657

Corporate Disclosure in Compliance with California Transparency in Supply Chains Act of 2010

CIVIL has a strong commitment to maintain an ethical work environment that promotes dignity and respect. We are focused on creating positive labor and environmental practices in our own facilities as well as the facilities of our suppliers.

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chain.

We employ the following practices to ensure we meet and exceed the requirements in the Transparency in Supply Chains Act.

Verification
One of our core values is to treat all our partners in a civilized way. Our corporate Code of Conduct specifically dictates that our suppliers refrain from the direct or indirect use of forced labor and any form of human trafficking. We require suppliers to certify that they comply with our Code of Conduct. As this is an important criteria in selection of suppliers we conduct our own verification or work with independent third-party audit firms.

Audits
Our suppliers are required to demonstrate adherence to the parts of our Code of Conduct that prohibits use of forced labor and human trafficking by permitting social and environmental audits. These audits are conducted by CIVIL employees and independent third-party audit firms.

Certification
We require that our direct suppliers agree to the part of our Code of Conduct that requires them to comply with all applicable laws and regulations and to provide a safe and sanitary workplace free from harassment and discrimination. Our suppliers must also certify that all materials incorporated into products they supply to CIVIL do not come from any forced labor, slavery or human trafficking.

Internal Accountability
We require our employees to stand behind our values and act in an ethical manner. CIVIL has no tolerance for violations of our Code of Conduct as it relates to slavery and human trafficking. Possible violations will be investigated and appropriate action taken, including possible termination of a violator’s relationship with CIVIL.

Training
We provide periodic training for our employees and management who have responsibility for supply chain management. Our training provides information concerning human trafficking and slavery, particularly with respect to mitigating the risks within the supply chain of products.