California Transparency Act

Chubbies is committed to the principles of enjoying the weekend, free choice of employment, non-discrimination, and humane treatment of all throughout every aspect of life and business. We have taken proactive steps to mitigate the risk of forced labor and human trafficking – defined by the United Nations as an act of recruiting, transporting, transferring, harboring, or receiving a person through the use of force, coercion, or other means for the purposes of exploiting them – in our supply chain.

Does Chubbies engage in the verification of its product supply chains to evaluate and address risks of human trafficking and slavery? Are these verifications conducted by a third party?

VERIFICATION

In order to verify that Chubbies product supply chains do not use goods produced by forced or child labor, factories are required to go through an approval process before they join our supply chain, including working with Sourcing and Quality Assurance departments to make sure the factories meet company standards. We’re as thorough as possible.

As part of this verification process, new and existing factories are audited by independent, third-party monitoring firms, which includes evaluating potential risks for human trafficking. The auditors are also monitoring to ensure that if the factory uses an employment agency, the factory and employment agency are in compliance with the local law. Any non-compliance is immediately brought to the attention of our leadership, and Chubbies requires the factory’s immediate attention for improvement. New factories must hold 3rd party audit verification prior to production. Existing factories are audited once per year, but we can visit more or less depending on the factory’s performance and track record.

Does Chubbies require suppliers & vendors to comply with company standards for trafficking and slavery in supply chains? Are Chubbies audits independent and unannounced?

AUDITING

To ensure all the factories in our supply chain are fulfilling their obligation to Chubbies’ Vendor Code of Conduct, we require that all vendors utilize independent, third-party monitoring firms to audit them regularly. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). All factories are audited once per year, but we can visit more or less depending on the factory’s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time.

Does Chubbies require direct suppliers to certify 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?

CERTIFICATION

Vendors are contractually required to adhere to Chubbies Vendor Code of Conduct, which requires all of our suppliers to warrant that the products they supply to Chubbies are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. When a vendor accepts a purchase order, they are confirming their compliance with our Vendor Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. We also have a zero-tolerance policy for bad vibes and being a drag, but that isn’t quite as important.

How does Chubbies maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking?

INTERNAL ACCOUNTABILITY

Chubbies has a zero-tolerance policy for forced labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory will take immediate steps to correct the problem ahead of proceeding with production. The factory is required to alert Chubbies on how they are correcting the issue and work directly with the Chubbies Senior Compliance Manager to ensure there are no recurrences. In addition, subsequent audits performed at the factory will reference the factory’s corrective plan to confirm the issue has been resolved.

How does Chubbies provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products?

TRAINING AND AWARENESS

All managers directly involved in Supply Chain or Compliance Management are required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks.

All Chubbies vendors have dedicated compliance teams responsible for ensuring they review the clause within our Vendor Code of Conduct regarding involuntary (forced) labor and human trafficking. Vendor compliance teams are also responsible for internal training on human trafficking and slavery, particularly with respect to mitigating risks within their factory network.