Responsible Sourcing

Supply Chain Sustainability

Brascom Statement on Slavery and Human Trafficking

Transparency in Supply Chains

Brascom as a Swiss-UK company decided to join The California Transparency in Supply Chains Act of 2010 (SB 657), effective January 1, 2012, that requires retail sellers and manufacturers doing business in the State of California to disclose their efforts to eradicate slavery and human trafficking from their supply chains for tangible goods offered for sale.

Verification

Brascom has a “Supplier Social Accountability Audit Checklist/Report”. Brascom uses the Checklist/Report to assess our suppliers’ practices with respect to its workers, including slavery and human trafficking. The Checklist/Report is sent to suppliers once a year and our Brascom Team follows-up with onsite inspections. Brascom does not use a third party auditor.

Audits

Brascom conducts audits of suppliers to evaluate supplier compliance with company standards for human trafficking and slavery in supply chains. Brascom vets all potential suppliers on multiple levels prior to bringing them into the supply chain approved vendor list. At the present time, Brascom audits are not independent and unannounced. Brascom may consider independent and unannounced audits in the future.

Certifications

Brascom requires suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking in the country or countries in which they are doing business. Brascom's Checklist/Report incorporates this requirement.


Internal Accountability

Brascom maintains internal accountability standards and procedures for employees and contractors. This standard is reflected in Brascom’s Code of Conduct. All employees are required to comply with Brascom’s Code of Conduct.


Training

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






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