California Supply Chain Act

4S Beauty Practices Consistent with California Anti-Slavery Law

In September 2010, the State of California approved a new law, the California Transparency in Supply Chains Act of 2010 (SB 657) designed to increase information made available by companies with regard to efforts to eradicate forced labor and human trafficking. 4S Beauty recognizes the problems and issues that slavery and human trafficking present and is committed to complying with the new law. 4S Beauty is concerned about addressing the issues arising from slavery and human trafficking in our immediate supply chain.  This includes strengthening and making appropriate workplace standards and policies for the manufacturers who make our products.

Our goal is to protect the human rights of workers involved in our supply chain, and to help individuals experience safe, fair and non-discriminatory working conditions. 4S Beauty is disclosing its specific actions in relation to five key points as each relates to 4S Beauty’s procurement.

Verification:

We are continually evaluating risks in our supply chain, including potential risk of forced labor and human trafficking. Our current formal approach to assessing risk in our supply chain utilizes Worldwide Governance Indicators from the World Bank, which incorporate factors like government effectiveness, rule of law, control of corruption and government stability that can affect the risk of non-compliance in facilities producing goods in that country. 4S Beauty also monitors risk through the facility auditing program and investigations.

Auditing:

Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Internal Accountability:

Suppliers, contractors and service providers are expected to act ethically, and all suppliers providing product for sale or use by 4S Beauty are required to comply with 4S Beauty’s Standards for Suppliers. We investigate issues and take the appropriate action to address those issues, up to and including termination of associates and termination of agreements with suppliers and contractors.

Training:

Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

The following are 4S Beauty actions related to each key point described in the Act for procurement of private label products:

Disclosure Number 1:

Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery.  The disclosure shall specify if the verification was not conducted by a third party. 4S Beauty evaluates and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. The verification process is more robust for suppliers of 4S Beauty’s private-label products, but in all cases 4S Beauty seeks to have its contractors covenant to comply with all applicable laws against slavery and human trafficking. When considering new factory partners and manufacturers in a new country for its private-label products, 4S Beauty vets it for political stability and port safety, known labor issues, safety for 4S Beauty employees and travel, and other factors.  This process is handled and verified internally and does not involve third party audits.

Disclosure Number 2:

Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.  The disclosure shall specify if the verification was not an independent, unannounced audit.

4S Beauty’s manufacturing agreement terms and conditions for its private label products provide 4S Beauty with the right to audit a supplier’s legal compliance, which includes the right to audit for compliance with antislavery and anti-human trafficking laws.  The right to conduct audits is not a part of the standard terms and conditions for other goods.  In general, an audit would not be independent and unannounced, although 4S Beauty have the option to enlist specialized assistance as needed.

Disclosure Number 3:

Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

4S Beauty recognizes the importance of protecting the human right of workers who produce the materials for our products and accordingly requires supplier compliance with all applicable laws.  Suppliers are obligated to comply with all laws and regulations, but although compliance with such laws is part of the general compliance obligation, there is no specific requirements for direct suppliers to provide certification that materials incorporated into products comply with laws regarding slavery and human trafficking.

Disclosure Number 4:

Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

4S Beauty considers fair labor practices an important part of human rights.  To date, there have been no known violations related to slavery or trafficking in any of our supplier facilities.

4S Beauty’s approach to fair labor violations focuses on monitoring with the goal of establishing compliance in the workplace environment.  In the event that a case of human trafficking or slavery would be detected in 4S Beauty supply chain, 4S Beauty has an escalation process in place contractually and has the ability to terminate any supplier who remains in noncompliance after failing to cure a notified breach.

Disclosure Number 5:

Provides company employee and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.  Designated managers with responsibility for human resources or other compliance will receive training as determined from time to time to be appropriate and necessary on human trafficking and slavery issues.

Conclusion

4S Beauty is committed to upholding human rights as we conduct our business.  We will update the disclosures to reflect 4S Beauty’s experience on preventing and addressing potential human rights violations in our supply chain, including in the areas of antislavery and anti-human trafficking.

 

Attention California Residents:

California’s Proposition 65 provides that California consumers are to be given particular warnings regarding products that contain chemicals known to the State of California to cause cancer or birth defects or other reproductive harm.

Some of the products we sell, such as: cosmetics, personal and fashion accessories, cosmetic cases, handbags, purses, travel goods, electronic goods, and other items containing imitation leather, vinyl, foam, synthetic and non-woven material, and other plastic components, may contain, lead and /or phthalate chemicals including but not limited to, DEHP, as well as other chemicals known by the State of California to cause cancer or reproductive harm.  In accordance with California’s Proposition 65, we issue the following warning to our California customer’s regarding these products:

WARNING: The above products may contain lead, phthalates and other chemicals known by the State of California to cause cancer and birth defects or other reproductive harm.