Apple & Eve LLC’s – California Transparency in Supply Chains Act of 2010

Corporate Disclosure

Apple & Eve LLC recognizes the pervasiveness of practices that could be construed as slavery and human trafficking, and we are committed to addressing the issues within our supply and distribution chains. With that, we comply with all applicable laws and regulations in the countries where we manufacture products and expect that our manufacturers, suppliers and/or vendors (collectively, “Supplier(s)”) and other business partners comply with applicable laws in the territories in which they operate. We would never knowingly do business with any Supplier who engages in human rights violations whether it involves the use of child labor, forced labor, discrimination, harassment, occupational health and safety, human slavery, or human trafficking issues. To assist in our further efforts to make sure these issues will not be present in our supply and distribution chains, we are in the process of solidifying a Supplier Code of Conduct to further cover issues such as maximum working hours, basic wage, respect, equality and restriction of forced labor and human trafficking, amongst others.

On September 30, 2010, California Senate Bill 657, also known as the California Transparency in Supply Chains Act of 2010 (the “Supply Chains Act”), was signed into law and codified in California Civil Code Section 1714.43 and California Revenue and Taxation Code Section 19547.5. The Supply Chains Act requires “retailers” and “manufacturers” conducting business in California, and conducting over $100,000,000 in worldwide sales, to publicly disclose what efforts they have taken to eliminate slavery and human trafficking from their supply and distribution chains. Pursuant to the requirements provided in the Supply Chains Act, we provide the following disclosures that discuss our efforts to combat slavery and human trafficking in our supply and distribution chains:

1. We at Apple & Eve LLC assess and evaluate the risks of human trafficking and slavery in our supply and distribution chains through various means, including (i) reviewing Supplier profile information, (ii) conducting certain internal quality assessments and (iii) conducting external compliance assessments through, among other things, inspections and tours of our current and potential Suppliers.
2. To assure that our Suppliers comply with (i) all applicable laws (including, without limitation, “wage and hour,” “health and safety” and “environmental” laws) within the country of business, (ii) international standards and (iii) all of our policies, procedures and/or regulations, we have conducted, or have caused a third party to conduct, inspections of Suppliers’ facilities. Further, we are currently working to solidify a Supplier Code of Conduct to issue to all our Suppliers, which will further enhance our monitoring plan for our Suppliers. The Code of Conduct will require, in writing, that each of our Suppliers agree to allow us and/or other third parties to engage in monitoring activities to confirm compliance with the provisions of the Code of Conduct and all applicable state and international laws, and will allow, among other things, unannounced on-site inspections of manufacturing, packaging and distribution facilities, reviews of books and records relating to employment matters, and private interviews with our employees and employees of our Suppliers.
3. We require all Suppliers to comply with all applicable laws (including, without limitation, “wage and hour,” “health and safety” and “environmental” laws) within the country of business, international standards and all of our policies, procedures and regulations. In doing so, we require Suppliers to agree to: (i) not to use child labor in manufacturing, packaging or distribution of their products; (ii) only employ persons whose presence is voluntary, and not to use any force or involuntary labor; (iii) treat each employee with dignity and respect, and not to use corporal punishment, threats of violence, or other forms of physical, sexual, psychological, or verbal harassment or abuse; (iv) not discriminate in hiring and in employment practices, including salaries, benefits, advancement, discipline, termination, or retirement, on the basis of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion, or disability; and (v) respect the rights of employees to associate, organize, and bargain collectively in a lawful and peaceful manner. Further, we periodically request and require that Suppliers provide written confirmation that they are in compliance with the applicable laws within the country of business, international standards and/or our policies, procedures and regulations regarding, among other things, human slavery and human trafficking.
4. To combat human trafficking and human slavery, we will maintain and enforce internal accountability procedures for employees and Suppliers regarding company standards in slavery and human trafficking. In the case of non-compliance, the company reserves the right to examine the specific situation and develop a best possible strategy for resolution. If cases of non-compliance are not resolved within a timely manner, we may terminate our business relationship with a non-complying employee and/or Supplier.
5. Apple & Eve provides basic informal training to ensure that necessary participants in supply and distribution chains management are knowledgeable and aware of the issues and concerns surrounding the supply and distribution chains, including human trafficking and human slavery.

In accordance to the new Supply Chains Act, we are dedicated to continuing our expansion of our standards and are taking various measures to better our policies, procedures and regulations, in an effort to ensure eradication of slavery and human trafficking in our immediate supply and distribution chains and eventually beyond. This will include strengthening, and making more explicit, our workplace standards and policies for the Suppliers of our products.