(Cal. Civil Code § 1714.43)
Ensuring that our manufacturing partners comply with international standards for social responsibility remains a high priority at Commemorative Brands, Inc./Taylor dba Balfour (“CBI/Taylor”). Accordingly, in connection with CBI/Taylor’s efforts to ensure that the goods we sell are not produced by workers who are enslaved, coerced, or otherwise forced into service, CBI/Taylor has implemented policies and procedures to manage supply chain reviews, supplier auditing, risk analysis, corrective actions, and management reviews, with at least annual frequency. CBI/Taylor discloses that it:
1. Engages third parties and internal assets for verification of product supply chains to evaluate and address risks of human trafficking and slavery. Each supplier is required to certify its compliance with the anti-slavery and anti-trafficking polices, by signing and returning the compliance form, this attests that each supplier is operating in compliance.
2. Engages internal assets to conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The audits are performed by CBI/Taylor employees and are not unannounced.
3. Requires all suppliers to certify that materials incorporated into CBI/Taylor products comply with the laws regarding human trafficking and slavery of the country or countries in which the suppliers are doing business. All of our suppliers must stipulate that they will abide by our anti-trafficking and anti-slavery policies and standards by signing and returning the compliance document.
4. Maintains internal accountability standards and procedures for employees failing to meet company standards regarding human trafficking and slavery. CBI/Taylor’s internal policies set specific standard for employee commitment to compliance with all laws and regulations applicable to our business activities and CBI/Taylor expects all employees to adhere to those standards. To facilitate accountability, employees are required to notify management, a direct supervisor, or human resources when they believe a violation of law or our policies has occurred. Further, CBI/Taylor promptly investigates all such reports and takes appropriate corrective measures and issues appropriate penalties when necessary. CBI/Taylor prohibits retaliation against any employee who makes a complaint or participates in an investigation.
5. Provides training on human trafficking and slavery to CBI/Taylor employees and management who have direct responsibility for supply chain management. This CTSA Human Trafficking and Slavery Education and Awareness training document focuses in particular on mitigating risks within the supply chains of products, and is based on the employee’s role and area of responsibility.
CBI/Taylor is committed to fair labor practices within our supply chain and to awareness regarding global risks of slavery and human trafficking. We continue to identify ways to improve both employee and supplier awareness of our efforts to prevent human trafficking and modern slavery.