California Transparency in Supply Chains Act of 2010
The California Transparency in Supply Chains Act of 2010 (SB 657) requires certain companies manufacturing or selling products in the State of California to disclose their efforts (if any) to eradicate forced labor and human trafficking from their direct supply chains for goods they offer for sale.
Forced labor and human trafficking can take many forms, including child labor. Hotheads, Beauty Industry Group and its affiliated companies doing business in California, (collectively, “BIG”), have a zero-tolerance policy for both forced labor and child labor used in the manufacture of all products that they sell. To further advance our commitment to human rights, BIG is a signatory of the United Nations Global Compact of businesses protecting human rights.
Through BIGs colleagues and across all the geographies in which we work, we are committed to maintain the most responsible business practices possible and constantly strive to deliver true, sustainable beauty to the world. Read more about BIGs commitment to transparency and traceability across the supply chain in the latest ESG report.
In order to work with BIG, vendors and their contractors in the U.S. and other countries are expected to operate in a manner that respects the rights of people and to abide by BIG’s Code of Conduct. This Code of Conduct requires that vendors and their contractors who provide products to BIG not engage in any labor practices that violate the laws and regulations of the country where the products are manufactured or assembled and not engage in any unsanitary or unsafe labor conditions. This Code of Conduct, which follows the U.S. Department of Labor regulations and the Fair Labor Standards Act, provides, among other things, that BIG’s suppliers and its contractors may not use or support child, indentured, involuntary, or prison labor in the manufacture of the products sold to BIG.
The BIG Code of Conduct is an integral part of the BIG Standard Vendor Agreement, BIG Purchase Orders, Import Letters of Credit, and BIG’s form Services and Consulting Agreements.
Additionally, BIG provides an annual Corporate Social Responsibility Report, a copy of which can be found HERE which details BIGs initiatives around an ethical supply chain.
II. Verification and Audit
Vendors and their contractors must maintain written records evidencing compliance with the provisions of the Code of Conduct and must make those records available to BIG upon request. This may include providing BIG with a copy of a third-party audit, which may be announced or unannounced, evidencing compliance with the Code of Conduct, including its child and forced labor prohibitions.
BIG leaders in the Supply Chain Department receive annual training on the Code of Conduct, which includes updates and discussions of child labor laws and their importance in sourcing goods.
Any employee who fails to abide by the forced and child labor provisions of BIG’s Code of Conduct will be subject to disciplinary action, which may include termination. BIG may terminate its relationship with a vendor found to be using child or forced labor to produce products that it sells (or attempts to sell) to BIG. That vendor will also be subject to damages resulting from breach of its agreement with BIG.