California Transparency in Supply Chains Act: Disclosure Statement
As of January 1, 2012, California’s Civil Code section 1714.43 (California Transparency in Supply Chains Act of 2010) requires manufacturers and retailers to provide information concerning their efforts to address the issues of forced labor, slavery, and human trafficking within the supply chain. The purpose is to allow consumers to make better and more informed decisions about the products they buy and the companies they support.
(1) Verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
Loami Nails LLC is committed to fair labor practices within our supply chain. We conduct annual assessments of 100% of our product suppliers to verify that they are not at risk of violating anti-slavery and human trafficking laws. We currently do not use third-party verifiers. Our own risk-management team spearheads the verifications process using an internally developed rubric and multi-part assessment.
(2) Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
Loami Nails LLC currently does not audit our product suppliers. As our business grows, our risk-management team plans to annually audit 25% of our direct supplier to evaluate their compliance with our anti-slavery and human trafficking company standards.
(3) Certification by direct suppliers that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
To ensure that Loami Nails LLC product suppliers respect and enforce our company standards, we ask that each supplier share any third-party certifications for fair labor practices with us. As a condition of continuing to do business with us, each supplier must additionally annually self-certify by signing a clause that states: 1) Supplier represents that it complies with all applicable laws and regulations; 2) Supplier represents that its supply chain and materials incorporated into its products comply with national and international laws prohibiting slavery and human trafficking; 3) Supplier agrees to treat workers with dignity and respect, provide them with a safe working environment.
(4) Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Non-compliance with Loami Nails LLC company standards regarding slavery and trafficking can result in corrective action or termination, depending on the number of non-compliances found and their severity. Our risk-management team will work with employees and contractors to develop action plans to resolve any such instances of non-compliance. While we believe in sustainable remediation, we reserve the right to terminate a business relationship with an employee or contractor if it is deemed necessary.
(5) Training of company employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
Loami Nails LLC CEO has read and understands the California Supply Chain Transparency Act and is currently responsible for ensuring our compliance. As our business grows and we gain new employees, we will provide training on slavery and human trafficking.