Brookwood Companies

California
Transparency
in Supply Chains Act

The California Transparency in Supply Chains Act requires large manufacturers and retailers doing business in California to publicly disclose the actions they are undertaking to identify and eradicate forced labor and human trafficking in their supply chains. The law’s purpose is to provide consumers with critical information about the efforts that companies are undertaking to prevent eradicate human trafficking and slavery in their product supply chains globally.

Brookwood is committed to fair labor practices in our supply chain and our actions in these areas are as follows:

Verification of Product Supply Chain
In order to verify compliance with Brookwood’s purchase order which expressly incorporates the Brookwood Supplier Code of Conduct (the “Code”) that forbids the use of child labor and specifies that “suppliers will not use forced labor, whether prison, bonded, indentured or otherwise and will not engage in or support trafficking in human beings, ”Brookwood reserves the right to access a Supplier’s factories and other sites. Additionally, per said terms, Brookwood may also audit the supplier’s records that pertain to purchases made by Brookwood. Per said terms, audits can be both announced and semi-announced and can be conducted through a third-party agency. Audits may review the supplier’s policies, procedures and record retention; labor and child labor policies and records; wage and benefits; work environment, including health and safety; environmental impacts and compliance with environmental regulations.

Certification
Brookwood does not currently require certifications from its suppliers. However, Brookwood’s Code requires our suppliers to maintain records to substantiate that all materials it supplies are produced in compliance with the anti-slavery and human trafficking laws of the country or countries in which they operate. Such records may include written policies and procedures that ensure adherence to all elements of the Code, as well as personnel files for every worker, including proof of age, executed employment contract (where necessary by law), and a true and accurate record of hours and wages.

Internal Accountability
Brookwood maintains and enforces internal accountability procedures for employees and suppliers regarding company standards in slavery and human trafficking. Brookwood’s Code specifically states the company’s support and comply with laws and regulations prohibiting forced, compulsory, and child labor. Brookwood does not permit violations of the law or the Code. Suppliers are expected to take necessary corrective actions to remediate promptly any noncompliance with Brookwood’s Code and Brookwood reserves the right to terminate its business relationship with any Supplier who is unwilling to comply with the Brookwood Code.

Training
Brookwood provides training to individuals who manage procurement and supply chain activities to ensure they understand the terms found in the Brookwood purchase orders. In addition, all employees are provided with a copy of the Code and are required to annually review and execute Brookwood’s Working Together Guide and Business Conduct Policy which includes the Code.