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California Transparency in Supply Chains Act

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Summary
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MINTED IS COMMITTED TO MAINTAINING THE HIGHEST LEVEL OF INTEGRITY THROUGHOUT OUR BUSINESS, AND WE SEEK THE SAME COMMITMENT FROM OUR PARTNERS. ONE OF OUR PRIORITIES IS TO ENSURE THAT THE PEOPLE WHO MAKE OUR PRODUCTS ARE TREATED WITH FAIRNESS AND RESPECT. WE WORK WITH SUPPLIERS WHO MEET OUR STANDARDS FOR SAFE, HEALTHY WORK CONDITIONS, AND WHOSE EMPLOYMENT PRACTICES CONFORM WITH LOCAL LAW AND BEST INDUSTRY PRACTICES. THESE STANDARDS INCLUDE A STRICT PROHIBITION AGAINST CHILD LABOR, PRISON OR FORCED LABOR, UNSAFE WORKING CONDITIONS, OR UNFAIR WAGE PRACTICES. 

The California Transparency in Supply Chains Act of 2010 (SB-657) requires retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their direct supply chain.  The purpose of the law is to educate consumers about the companies they purchase goods from so that they can make informed purchasing decisions.

Verification

We are committed to ensuring that our supply chain is free from human trafficking and slavery and for ensuring that all suppliers meet Minted’s Minimum Compliance Standards (MMCS). We communicate MMCS to all suppliers annually, and engage in regular efforts to identify, assess and manage the risks of human trafficking and slavery in the production of our products. We evaluate supplier partners based on a variety of factors, including regular visits at their site from members of management and other Minted employees, the suppliers' geographical location and manufacturing process, a workforce profile and the history of human trafficking and slavery in the sector. We do not currently use third-party verifiers. Our own risk-management team spearheads the verification process using an internally developed rubric and multi-part assessment. Our risk-management team is currently unable to verify whether our subcontractors use labor brokers.

Audits

We engage in audits of our suppliers on an as needed basis to assess whether such supplier engages in human trafficking and slavery. In the event that a potential violation of human rights is identified, Minted will promptly address the issue with the supplier and set expectations for how the situation is to be addressed. If a non-compliance issue were not resolved in a timely manner, then Minted would re-evaluate its business relationship with the supplier, up to and including termination of the business relationship.

Certification

To ensure that our contractors and suppliers respect and enforce our company standards, we include a clause in our standard commercial agreement that require suppliers to certify that they will perform their obligations to Minted in compliance with "all applicable federal, state, county, or local laws, statutes, rules, regulations, ordinances and requirements promulgated by governmental or other authorities including any judicial or administrative interpretations thereof." We also reserve the right to immediately terminate an applicable agreement if we were to determine that a supplier is non-compliant.

Internal accountability

We have not yet developed formal internal accountability standards and procedures for employees and contractors failing to meet our company standards regarding slavery and trafficking. However, if and when we were to uncover employee or contractor compliance problems, we would provide written notice and a specified period of time to take corrective action.

Training

Our company does not currently provide employees or contractors with training on human trafficking and slavery, but are currently establishing training protocols to be implemented.

Minted’s Minimum Compliance Standards

For all Supply Chain partners, Minted has a zero tolerance policy for:

-Child Labor: Any confirmed current employment of underage workers or any inappropriate remediation of child labor violations under applicable laws.

-Involuntary Labor: Any confirmed current employment of forced, bonded, indentured, or prison labor; mandatory or involuntary overtime, or imposition of penalties or fines for refusing overtime; withholding of personal property (e.g., passport, identification papers) or wages; or unreasonably limiting freedom of movement during and/or after work hours.

-Coercion and Harassment: Any policy permitting, or the actual the use of, corporal punishment; threats of termination of employment; the imposition of penalties or retaliation as disciplinary action; or intrusive or intimidating security practices.

-Discrimination: Discriminatory hiring and employment practices (e.g., salary, benefits, advancement, discipline, termination, or retirement) on the basis of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion, disability, pregnancy, or union membership. 

-Association: Policies or practices that prevent employees from exercising their legal right to associate, organize, and bargain in a lawful and peaceful manner in accordance with applicable laws; retaliation for the exercise of any such right.

-Health and Safety: Conditions in the Facility, including dormitories, that could cause immediate severe injury or death to employees or the public

-Subcontracting: Any use of another Facility or other source for production without authorization from Minted. 

-Monitoring and Compliance: Any effort to withhold accurate information from Minted (e.g., Failure to provide true and complete records for review; or failure to permit auditor access to required documents, private employee interviews, or health and safety inspection of the entire Facility.)

These areas can be collectively defined as “Minted’s Minimum Compliance Standards” (MMCS). If a partner is found in violation of any part of the MMCS, Minted will provide a Corrective Action Plan. Minted reserves the right to cease production until the violation is resolved, or to end the business relationship.

Minted communicates its Supply Chain Policy and MMCS to all partners on an annual basis.

TitleCalifornia Transparency in Supply Chains Act
URL NameCalifornia-Supply-Chain-Act

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