Many companies manufacturing or selling products in the State of California are required to disclose their efforts (if any) to address the issue of forced labor and human trafficking, per the California Transparency in Supply Chains Act of 2010 (SB 657). This law was designed to increase the amount of information made available by companies regarding efforts to eradicate forced labor and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support. Forced labor and human trafficking can take many forms, including child labor. Kenzies of London has a zero-tolerance policy for both forced labor and child labor used in the manufacture of all products that we sell.

I. POLICY

We are committed to ensuring that the products we sell are manufactured without the use of child, involuntary, or slave labor.

II. SUPPLIER CODE OF CONDUCT

All vendors that provide products to Kenzies of London are required to certify to Kenzies of London’s Supplier Code of Conduct (the Code), which forms a part of the legal terms and conditions for each order that Kenzies of London places, and which provides, among other things, that Kenzies of London’s suppliers may not use any form of child, involuntary, or slave labor in the manufacture of the products that we sell. Kenzies of London extends this restriction to the manufacturers of finished goods that are produced for Kenzies of London’s suppliers.

III. RISK EVALUATION

We source our products from many individual suppliers. Because of the range of our retail business, we take a variable, risk-based approach to auditing companies within our supplier base. Our enforcement process, which is described below in more detail, considers a number of factors relevant to determining relevant risks related to forced labor and child labor.

IV. AUDIT AND ENFORCEMENT

We work with small businesses and carefully vet the use of child labor in the manufacturing of our products. Many of our suppliers offer a tour of their factories prior to us working with them. We also receive pictures of works in progress that display the production process of our goods. These photographs may have factory employees in them. Pandemic restrictions have made it difficult to carry out audits of each of these factories. However, when these restrictions lift, we plan on carrying out inspections every 2 years. They will be scheduled in advanced with the suppliers and will include an on-site visit to view factory conditions. In the event that any supplier is found to have used child, involuntary, or slave labor in the manufacture of products supplied to us, we are prepared to immediately cancel all outstanding orders with such supplier. 

V. EMPLOYEE TRAINING AND ACCOUNTABILITY

All of our global sourcing staff who have direct responsibility for supply chain management, as well as certain other groups of employees who are indirectly involved in sourcing, are required to complete a training program with regard to the Code and our enforcement of it. Any employee who fails to abide by Kenzies of London’s procedures regarding forced labor will be subject to disciplinary action, including potential termination.