SUPPLY CHAIN TRANSPARENCY STATEMENT

California Transparency in Supply Chain Act Disclosure
Social and Ethical Responsibility

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

At J.McLaughlin, we consider it a brand imperative to source and manufacture our products in a legal and ethical manner. To that end, it is a condition of doing business with J.McLaughlin that any and all suppliers, vendors and partners comply with and conduct business in conformance with our vendor business requirements outlined in the J.McLaughlin Vendor Code of Conduct. We clearly communicate these expectations to ensure our valued business partners abide by the highest standards of ethical, social, and legal behavior.


We are proud of our efforts to help improve working environments and practices around the globe and believe these efforts give our customers even more confidence in their decision to purchase J.McLaughlin products. We are happy to provide you with more information if requested.


In accordance with the California Transparency in Supply Chains Act of 2010 (SB 657), J.McLaughlin is providing the following information about our efforts to address prohibition against human trafficking and the use of slave labor within our supply chain. The purpose of this disclosure is to provide our customers with accurate information to make informed decisions when they shop with us.

1. Verification of Product Supply Chains

J.McLaughlin adheres to a Code of Conduct to address social and ethical standards regarding health and safety, discrimination, disciplinary practices, sourcing, human trafficking, and slavery within the supply chain.


Each manufacturing facility, including subcontractors, must periodically submit documentation outlining where our products are manufactured and which provides details regarding the work practices of its sourcing partners. J.McLaughlin will only utilize sourcing partners who provide workers with a safe and healthy working environment. Our manufacturing facilities and their subcontractors have assured us that all workers in all cases are employed voluntarily, compensated fairly, not at risk of physical harm, allowed the right of free association, and are not exploited in any way. J.McLaughlin actively seeks to associate with and utilize sourcing partners who meet or exceed our social and ethical standards.


Comparable to other retailers, our supply chain is multifaceted and we have less visibility of indirect suppliers as opposed to our direct suppliers. To ensure compliance with our Code of Conduct, we frequently communicate with our various mill and trim suppliers to detect risks of noncompliance. We also require all suppliers to agree to conduct business practices in conformance with our vendor business requirements.

2. Supplier Audits in Product Supply Chains

J.McLaughlin maintains overseas quality assurance and compliance by ensuring that its associates are devoted to social responsiveness through factory audits and training. They also make it their job to constantly find ways to improve all facilities associated with J.McLaughlin. We maintain long-standing business relationships with several overseas factories which have been, and routinely continue to be, inspected to ensure the highest standards of social and ethical compliance. Before beginning a business relationship with a new factory, our Quality Assurance team performs a heightened audit to determine compliance.


Suppliers and contractors are required to permit representatives of J.McLaughlin complete and uninhibited access to employees and the workplace at any time to perform inspections. Suppliers and contractors must keep and maintain thorough records of employment history including hours worked, wages paid, and other relevant information. Indirect suppliers must certify factory compliance prior to working with J.McLaughlin.


When issues of social and ethical non-compliance are determined, it is J.McLaughlin’s business practice to terminate the relationship immediately.

3. Certification of Compliance in Product Supply Chains

J.McLaughlin will only pursue business relationships with suppliers who agree with our business practices and standards. Our vendor business requirements set forth the policies and procedures we expect from our suppliers. These requirements align with the highest standards regarding ethical and social responsibility. Our vendors are contractually obligated to comply with these standards, ensuring compliance with health and safety, sourcing, disciplinary practices, and prohibition against discrimination, human trafficking, slavery and coercion within the supply chain.

4. Internal Accountability

All J.McLaughlin associates who play a direct role in the development of our products are required to complete our social and ethical policies and standards training. Associates are expected to comply with these standards at all times. Failure to conform with our Code of Conduct and business practices could result in corrective action or termination.


J.McLaughlin seeks to partner with vendors and suppliers who understand and comply with our social and ethical polices and standards. Vendors are contractually obligated to conform with these policies that are set forth in our vendor business requirements. Failure to comply with our Code of Conduct and business practices could result in corrective action or termination.

5. Training

J.McLaughlin is devoted to informing associates who have direct responsibility for supply chain management of our social and ethical standards. We conduct annual training seminars for these associates on our social and ethical requirements and how to properly manage and inspect suppliers to achieve our standards and ensure compliance throughout the supply chain.