CA Supply Chain Act
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT – GOOD AMERICAN LLC. COMPLIANCE STATEMENT
Good American LLC. ("Good American") is committed to ensuring transparency and ethical practices within its global supply chain to prevent modern slavery and human trafficking. As part of its commitment, Good American declares its support for the California Transparency in Supply Chains Act of 2010, Section 3 , and the United Kingdom (UK) Modern Slavery Act 2015, Chapter 30, Part 6, Provision 54 . Verification and a summary of measures concerning audits, internal accountability, and training are provided below. For more information on the company's organizational structure and the approach to Social Responsibility, please reach out to our VP of Production & Sourcing mailto:[email protected]
Verification Process
Good American is committed to upholding high ethical standards within its global supply chain and ensuring that, as a zero-tolerance policy, modern slavery and human trafficking are not present in any of its operations. Good American regularly engages in verification activities to identify and manage any potential risks, including through unannounced third-party assessments. As such, Good American requires all Vendors to adhere to its Code of Conduct and Master Agreement which contain policies and benchmarks. As the basis of each partnership, all Vendors must deploy the Code of Conduct upstream to their factories. Good American monitors compliance with this Code of Conduct through its Corporate Social Responsibility Program.
Supplier Assessments
Good American maintains an ongoing monitoring system to identify and address potential supply chain risks through initial and annual independent third-party assessments. All supply chain partners of Good American are expected to implement internal controls to ensure they comply with our Code of Conduct requirements.
Factory assessments include five categories: labor rights, employee health & safety, environment, ethics, and management systems. The labor standards comprise regulations relating to forced labor, child labor, working hours, wages and benefits, abuse and harassment, non-discrimination, and freedom of association. The Good American Code of Conduct & Compliance Benchmarks provide detailed information on all categories and subcategories, including workers' rights relating to freedom of association and collective bargaining in accordance with the International Labor Organization (ILO) conventions on fundamental principles and rights at work. It also outlines the necessary measures and management system requirements to protect workers' rights. Modern Slavery and Human Trafficking are captured under the forced labor topic of the same document: Good American will not work with any vendors/factories that use any forced or involuntary labor, whether imprisoned, bonded, trafficked, indentured, or otherwise.
Internal Accountability
Good American has established a compliance program that incorporates anti-trafficking policies. We have implemented procedures to ensure that employees and contractors adhere to these policies. References to the applicable Good American Workplace Code of Conduct and Compliance Benchmarks Policy provide the necessary context for this disclosure.
Non-compliance with the Good American Code on slavery and trafficking is considered a zero-tolerance supplier violation and is taken very seriously. We require immediate corrective action plans (CAPs) from our Suppliers to remediate identified non-conformances. Good American works with suppliers through root cause analysis until the non-compliance is resolved and confirms this through a follow-up assessment.
- Consequences: Good American maintains a range of consequences for employees or contractors found to have violated anti-trafficking policies. If a Supplier fails to resolve the non-compliance after two follow-up assessments, they will be subject to a disengagement process, removing them from the approved Good American Supplier-Factories List.
- Reporting Procedures: Good American has established reporting procedures, including an internal and third-party compliance email, to allow employees, suppliers, and stakeholders to report concerns or potential violations. These procedures are available in multiple languages, ensuring accessibility.
- No-Retaliation Policies: Good American has no-retaliation policies in place to protect individuals who report concerns or violations in good faith.
Training and Capacity Building
Good American believes in the importance of continuous education and capacity building will provide training to suppliers and applicable employees on identifying and mitigating risks related to human trafficking and slavery in the supply chain.
All Good American employees within the Global Sourcing, Planning, Procurement, and other relevant teams will undergo periodic training on company standards as they relate to its global supply chain, including but not limited to recognizing and preventing forced labor, responsible purchasing practices, and assessment and remediation procedures.
Our dedicated B Corp Compliance team plays a vital role in ensuring adherence to global compliance standards. They regularly participate in external seminars, webinars, and training sessions providing insights and updates on current international compliance practices. This ongoing education enables our B Corp Compliance team to stay informed about emerging issues, best practices, and regulatory developments related to supply chain transparency and responsible sourcing.