California Transparency in Supply Chains Act

CALIFORNIA SUPPLY CHAINS ACT
EAGLE PROTECT PBC

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. The Act requires large manufacturers and retailers doing business in California to publicly disclose the actions they are undertaking to ensure their product supply chains are free from human trafficking and slavery. The law was designed to increase consumer’s knowledge about products they buy and the companies they choose to support. While Eagle Protect does not meet the sales volume required to follow this Act, it aligns well with its core purpose and thus follows all requirements.

Verification

Eagle Protect is committed to fair labor practices within its supply chain. We personally visit our suppliers to identify and evaluate the potential risks for human trafficking and slavery in our supply chain.

These regular supplier visits allow the Eagle Protect team to measure its suppliers’ compliance with our Supplier Code of Conduct. The Supplier Code of Conduct forbids the use of child labor under the age of 15 years and states there shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. Before partnering with any new suppliers, they are put through our audit process before placing any production orders with them.

We are currently going through the process of getting our glove suppliers Child Labor Free approved. Products certified with the Child Labor Free mark provides assurance that brands carrying that mark are committed to operating ethically and ensuring their business is free of child labor.

Supplier Audits

Auditing our suppliers is a key part of our supply chain, ensuring they adhere to our Supplier Code of Conduct.

During our visits, we audit our suppliers to determine if they are complying with our company standards and ensuring human trafficking is not tainting our products.

Eagle Protect staff also perform extensive announced audits in-house. Our audits review labor and working conditions, discrimination, wages/benefits and hours of work, environmental responsibility, health & safety, traceability and quality control.

If we believe that one of our suppliers is not in compliance with our Supplier Code of Conduct we will provide each supplier with the opportunity to remedy any non-compliance areas through the implantation of a corrective action plan and we require proof that the area has been remedied. Should the supplier continue to fail to meet our standards, we will take action to eliminate that supplier from our supply chain.

Certification

To ensure that our suppliers respect and enforce our company standards we include a schedule in our Supplier Code of Conduct, which stipulates that our suppliers must abide by our anti-slavery and human trafficking standards.

1) Supplier represents that it complies with all applicable laws and regulations, including eradication of forced, indentured, involuntary or compulsory labor in its facilities, and requires its suppliers, including labor brokers and agencies, to do the same;

2) Supplier represents that its supply chain and materials incorporated into its products comply with national and international laws prohibiting slavery and human trafficking; and

3) Supplier agrees to treat workers with dignity and respect, provide them with a safe work environment, conduct business in compliance with applicable environmental, labor and employment laws, and refrain from corrupt practices and engaging in human rights violations’.

Our suppliers must produce these records to our company auditors upon request. Such records may include: (1) proof of age for every worker; (2) every employee’s payroll records and timesheets; (3) written documentation of terms and conditions of employment; (4) local health and safety evaluations or documentation of exemption from law; and (5) records of employee grievances and suggestions, and any employer responses.

Internal Accountability

Eagle Protect maintains and enforces internal accountability procedures with its staff members and suppliers regarding our company standards in slavery and human trafficking. When a new staff member is inducted a review of our Supplier Code of Conduct and audit process is part of their internal training.

Non-compliance with our Supplier Code of Conduct regarding slavery and trafficking can result in corrective action or termination of our supply contract depending on the number of non-compliances found and their severity.

Our internal auditors work with our suppliers to develop their Corrective Action Plan to resolve any non-compliance areas.

Training

Eagle Protect is constantly developing its systems to educate and raise awareness of its Supplier Code of Conduct.