California Transparency in Supply Chains Act

California’s Civil Code section 1714.43 (California Transparency in Supply Chains Act of 2010) requires manufacturers and retailers to provide website 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. The California Transparency in Supply Chains Act requires manufacturers and retailers, including American Textile Company (“ATC”), to inform the public as to how it has addressed the following issues:

(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.

(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.

(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.

(4) Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

(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.

ATC has fulfilled the requirements of the California Transparency in Supply Chains Act through a full description of our processes set forth below.

CA Transparency in Supply Chains Act Disclosure Statements

(1) Verification of product supply chains to evaluate and address risks of human trafficking and slavery.

ATC uses an independent third-party in its verification activities to identify, assess and manage risks of human trafficking in its product supply chain and to evaluate the risk of noncompliance in slavery, human trafficking and other human rights and labor issues.

(2) Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.

ATC has an independent third party audit its suppliers’ compliance with ATC’s standards for human trafficking and slavery in its supply chain.  Our suppliers are on varying audit schedules which are scheduled, announced and confirmed with our suppliers.

(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.

Our direct suppliers are required to sign a comprehensive agreement which, among other things, requires them to comply with all applicable laws (which include those regarding slavery and human trafficking).

(4) Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

ATC maintains internal accountability standards and procedures applicable to both employees and contractors who may fail to meet company standards.  If an employee fails to meet the accountability standards and procedures they are subject to disciplinary action which may include termination.  If a contractor is in breach of our accountability standards and procedures, the contractor must cure all violations in a timely manner consistent with their contractual obligations or we may terminate our relationship with them.

(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.

We conduct specific training on human slavery and trafficking and on our Code of Conduct with employees and management teams, including our sourcing teams that have a relationship with our suppliers.