On January 1, 2012, California enacted a new law requiring companies of a certain size to publicly
disclose the steps they are taking to identify and eradicate forced labor in their supply chains. Premium
Brands Opco LLC (“the Company”) aligns with the intent of the legislation, and we are pleased to share
our continuous work towards sourcing products free of slavery and human trafficking.
At our Company, we understand that both our Associates, and our Customers, genuinely care about the
conditions under which our products are manufactured. It is important to us, , that materials used in our
products are obtained through ethical labor conditions. Our Code of Conduct for Merchandise Suppliers
(“Code of Conduct”) provides suppliers with our expectations for responsible manufacturing standards.
We only align ourselves with suppliers who share this commitment. Our Code of Conduct clearly states
that our Suppliers must not use involuntary or forced labor, whether indentured, bonded, prison, or
labor obtained through slavery and human trafficking.
We are taking the following actions to mitigate the risks of human trafficking and slavery in our direct
product supply chain:
- VERIFICATION OF PRODUCT SUPPLY CHAINS: The Company has a robust on-going internal risk
assessment program conducted by our Social Responsibility department. Our team reviews the U.S.
Department of State’s annual report on Trafficking in Persons, as well as the recommendations put
forward by the Department of Labor’s List of Goods Produced by Child Labor and Forced Labor, in
addition to other sources. When considering new sourcing countries, we follow a strict approval process
involving multiple departments and based on various criteria, including social compliance risks.
Additionally, all new private label factories must be reviewed by the Social Responsibility department for
social compliance before production may begin. The Company is proud to be a buyer partner of the
Better Work Program, a collaborative factory monitoring initiative led by the International Labour
Organization (ILO). We utilize audits conducted by the Better Work inspectors to assess factory
compliance in key manufacturing countries where the program is active. - AUDITING: We, or our partners, regularly conduct independent, unannounced and semi-unannounced
audits using third party service providers. We survey our suppliers to assess their use of migrant and
foreign contract workers. Our service providers follow procedures to identify non-compliance issues
found specifically within these classes of workers, such as hiring process issues and access to grievance
systems. An important aspect of the auditing process is worker interviews, conducted both on-site and
off-site. Whenever serious issues are found, suppliers are expected to engage in remediation and training which includes a corrective action plan specifically designed to address the risk in their supply - chain. In addition, we apply our rating system, which impacts business volumes, and provides guidance
- to the Company’s Sourcing department, assisting them in placing business with suppliers that achieve
- favorable compliance scores, and reducing business for poor performers. We have and will terminate
- factories with significant issues when there is insufficient evidence of improvement.
- SUPPLIER CERTIFICATION: All Vendors are bound by contract, and do represent and warrant in our
agreement, to abide by all applicable employment and human rights laws, as well as our Code of
Conduct, which, among other things, prohibits the use of child labor and forced or involuntary labor,
forced overtime, discrimination, or bonded or prison labor. The Code of Conduct emphasizes the
importance of well-treated, fairly compensated workers. Our Social Responsibility program seeks to
promote the maintenance of these standards in our manufacturing facilities and assesses compliance
with our Code of Conduct. - MAINTENANCE OF INTERNAL ACCOUNTABILITY STANDARDS AND PROCEDURES: The Company Code
of Business Conduct, distinct from the Code of Conduct of Merchandise Suppliers, is a guideline for
ethical business conduct and how we do business. This Code of Business Conduct is a summary of basic
principles for working in a way that reflects our Company’s commitment to ethics and integrity.
Associates are trained and required to report any suspected violations of the Code of Business Conduct,
and such reports may be submitted in writing or made to the Corporate Governance Hotline that is
available to all associates. - STAFF TRAINING ON IDENTIFYING AND PREVENTING SLAVERY AND HUMAN TRAFFICKING: Relevant
trainings are conducted for associates that engage regularly with vendors. These trainings include
webinars or eLearning which address risks of forced labor and human trafficking. Vendors participate in
training through our on-boarding process, and are trained more frequently when related risks are
identified