California Transparency in Supply Chain Act of 2010
The California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code 1714.43 and Cal. Rev. Tax Code 19547.5) was designed to ensure that manufacturers and large retailers provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains, to educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains, and thereby, to improve the lives of victims of slavery and human trafficking.
Slavery and human trafficking are issues that Drybar takes very seriously. Our supply chain staff actively manage and oversee our supply chain to ensure that our corporate responsibility standards are upheld.
Drybar therefore makes the following disclosures pursuant to the California Transparency in Supply Chains Act:
- Drybar is committed to fair labor practices within our supply chain. While we do not implement a formal process to verify the entities in our supply chain, Drybar does require that its manufacturers and material suppliers certify that they will comply with our Supplier Code of Conduct, which prohibits slavery and human trafficking. Occasionally, Drybar will permit a manufacturer to certify that it will comply with its own code of conduct instead of Drybar’s Supplier Code of Conduct, provided the manufacturer’s code of conduct is at least as stringent as Drybar’s Supplier Code of Conduct when it comes to issues of slavery and human trafficking.
- New suppliers undergo a social compliance audit, which includes an assessment of its practices to avoid modern slavery and human trafficking. Suppliers are expected to designate management staff to monitor their factories, production facilities and compliance with our Supplier Code of Conduct. Drybar may conduct a mix of announced or unannounced visits and/or have independent third-parties audit to help determine compliance with the Supplier Code of Conduct, including prohibitions on slavery and human trafficking. The number of assessments follows our risk-based approach and is dependent on the level of project activity awarded throughout the year. If gaps are identified, we may work with suppliers to help them understand how to close those gaps or we may ultimately consider terminating the contract. Suppliers that are required to develop a corrective action plan may be subject to additional audits, which may be announced or unannounced, as part of Drybar’s monitoring efforts. In addition, we may seek to terminate contracts with immediate effect if suppliers breach, or we suspect they are in breach, of Drybar’s Supplier Code of Conduct.
- Drybar requires its manufacturers and suppliers to certify that they will comply with all applicable labor regulations in the country in which they operate, as well as with Drybar's Supplier Code of Conduct.
- Drybar’s supply chain employees undergo an annual training educating them on how to identify evidence of slavery and human trafficking. Employees are asked to report any violations to the Senior management, which will then investigate and take all appropriate and necessary steps. Employees may also report such concerns anonymously through Drybar’s ethics hotline which is managed by an independent third-party and is available twenty-four hours a day.