Corporate Disclosure in Compliance with SB 657 California Transparency in Supply Chains Act (Human Trafficking and Anti-Slavery) 

TFG Holding, Inc. and all of its affiliates and subsidiaries (collectively “TFG”) strive to conduct business in an ethical and socially conscientious manner while also complying with all applicable federal, state and international laws. TFG asks that its suppliers in contracting, subcontracting and other business relationships also conduct themselves under the same beliefs and standards.  

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 went into effect, requiring retailers and manufacturers above a certain size that are doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains. The disclosure is aimed providing information to consumers, allowing them to make informed choices concerning the products they buy and the companies they support. 

TFG has created and implemented an Ethical Sourcing Code for merchandise vendors and factories that supply products to TFG. The TFG Ethical Sourcing Code outlines the expectations and requirements that TFG imposes on its suppliers that operate around the world. The Ethical Sourcing Code includes topics such as compliance with laws, child labor, voluntary labor, employee labor rights, living wages, freedom of association and collective bargaining, working hours, harsh and inhumane treatment of workers, discrimination, environmental standards and business integrity. The Ethical Sourcing Code also addresses and prohibits any form of slavery or human trafficking. To ensure compliance with the Ethical Sourcing Code, TFG subjects its suppliers to random unannounced inspections and audits.  

Verification 

The TFG Ethical Sourcing Code requires suppliers to refrain from the direct or indirect use of forced labor or any form of human trafficking and certify compliance with this requirement. TFG also requests that its suppliers implement procedures to manage the materials, including all labor related processes, incorporated into their products to ensure compliance with laws on slavery and human trafficking. 

Auditing 

To evaluate supplier compliance with TFG standards against trafficking and slavery in the supply chain, TFG subjects its vendors to random unannounced audits either by a TFG employee/representative or by an approved third-party audit firm. 

Certification 

The TFG Ethical Sourcing Code requires suppliers to certify that the products they produce do not directly or indirectly use any form of forced labor or human trafficking and that the supplier has procedures in place to manage the materials, including all labor related processes, incorporated into their products to ensure that they comply with laws on slavery and human trafficking. 

Internal Accountability 

TFG requires all its employees and employees of its affiliated brands to comply with all applicable federal, state and international law, any employee found to be in violation of any law prohibiting slavery or trafficking is subject to disciplinary action and termination. Contractors or suppliers violating the TFG Ethical Sourcing Code, including the prohibition against slavery and human trafficking are subject to investigation and appropriate action up to and including termination of association and termination of agreements for supplies with the violating party. 

Training 

TFG believes in the importance of continuous education and provides training to its suppliers, employees and decision-makers on an ongoing basis. TFG is committed to responsible and ethical sourcing for its merchandise and thus provides training to employees and decision-makers involved in placing purchasing orders and selecting suppliers. These employees and decision makers are made aware of the impact of their decisions that can affect factory working conditions in other countries. In addition, these employees and decision makers are trained and educated on the laws.