California Transparency in Supply Chains Act
CircleSaver, recognizes there are different legal and cultural environments in which our vendors operate throughout the world. We expect all vendors demonstrate a commitment to lawful and ethical business practices as specified in our Business Partner Code of Conduct. CircleSaver, requires all contract to manufacture vendors, their subcontractors, and finished good suppliers to meet or exceed the requirements outlined in our Business Partner Code of Conduct. Our Business Partner Code of Conduct covers a range of standards and practices including wages and benefits, safe working environment, non-discrimination, and prohibition of the use of involuntary labor of any kind.
We take a risk-based approach to evaluate and address risks of human trafficking and slavery for our contract to manufacture vendors. Elements of our internal risk evaluation include country of manufacture, product type, and size of manufacturer.
We monitor and enforce our Business Partner Code of Conduct by utilizing an independent third party to audit for compliance. The audits are scheduled in advance and include onsite visits and reviews of any involuntary labor as well as other aspects of our Business Partner Code of Conduct.
CircleSaver employees must understand and comply with the Eversley Retail Group Inc. Code of Conduct, which mandates compliance with legal and ethical standards. Failure to abide by the Eversley Retail Group Inc. Code of Conduct will lead to employee discipline up to and including termination.
All employees who have direct responsibility for supply chain management or sourcing and managing relationships with certain vendors are required to complete a training that enables them to identify and address human trafficking and slavery.