CA TRANSPARENCY IN SUPPLY CHAINS
PLBY Group, Inc. and its subsidiary companies (collectively, “PLBY”) respect and promote fundamental human rights and are committed to ethical business relationships, responsible sourcing and manufacturing, and environmental stewardship across all aspects of PLBY’s supply chain operations.
For certain companies like PLBY who manufacture and sell consumer products in the State of California, these companies are also required to comply with the California Transparency in Supply Chains Act of 2010 (“CTSCA”). Pursuant to the CTSCA, companies must disclose their efforts to evaluate and address the risks of human trafficking, child labor, forced labor, and slave labor in their product supply chains.
As further detailed in the disclosure statement below, PLBY is fully committed to ensuring that the products it sells are not sourced or manufactured as a result of any human trafficking or the use of any child labor, forced labor, or slave labor.
- Verification of Vendors
PLBY engages in verification of product supply chains relating to human trafficking and slavery through personnel who are employees of PLBY. For each vendor that PLBY contracts with to manufacture products (collectively, “Vendors”), the Vendor must provide key information and certifications regarding their manufacturing sites, origin of products/components, and sourcing practices. Prior to conducting new business with PLBY, each Vendor must review and sign a “Vendor and Manufacturer Contractual Commitment” (“VMCC”), whereby the Vendor makes certain representations and warranties regarding its monitoring and compliance with applicable laws and regulations. Each Vendor is requested to disclose important information such as the specific location address for its manufacturing site(s), contact information for Vendor’s designated personnel, the ownership structure of Vendor, Vendor’s manufacturing capabilities, and Vendor’s most recent corporate social accountability compliance audit results. Additionally, Vendors must not use subcontractors for the manufacture of PLBY products without the prior written approval of PLBY, and such approval is only issued after the subcontractor has provided PLBY with any other information or certifications that PLBY may request.
- Code of Conduct Compliance
PLBY requires Vendors to review and accept PLBY’s “Code of Conduct”, which is attached to the VMCC. Some pertinent provisions of the Code of Conduct include:
- Vendors will respect the rights of minors and only employ individuals ages 16 or older, including but not limited to the farming, harvesting, processing or other manufacture of materials or components throughout the supply chain. The use of workers 15 or younger is strictly prohibited. Workers under the age of 18 will not be in positions or have job duties with hazardous conditions, including but not limited to, working night shifts, using heavy equipment, or managing hazardous chemicals. Vendors will also comply with any laws and regulations that provide restrictions applicable to age.
- Vendors will respect the fundamental right of freedom and will not use forced or involuntary labor, whether prison, bonded, indentured, trafficked or otherwise, in the manufacture of products, including but not limited to, the manufacture of materials or components throughout the supply chain.
- Vendors will treat each employee with dignity and respect, and will not use corporal punishment, threats of violence or other forms of harassment or abuse, including but not limited to, physical, sexual, psychological, or verbal forms.
- Reports & Audit
PLBY relies on reputable third-party social compliance auditors to independently evaluate Vendor and manufacturing site compliance with PLBY policies, applicable laws, and industry standards. For example, Vendors are requested to provide PLBY with recent corporate social responsibility manufacturing site audit reports from a reputable third-party, or PLBY may send its own third-party representative to inspect Vendor’s manufacturing site or any other locations where products are manufactured. Such audits or inspections will include a review relating to Vendor’s compliance with PLBY’s Code of Conduct with specific focus on workplace conditions and any use of forced labor, child labor, or slave labor. PLBY will immediately cancel any purchase orders and take other applicable action consistent with PLBY’s “Supply Chain Incident Response Plan” in the event that any audit or inspection reveals or confirms the Vendor’s use of child labor, forced labor, or slave labor, or other violation of the Code of Conduct.
PLBY requires Vendors to certify that materials incorporated into manufactured products comply with the applicable laws regarding slavery and human trafficking of those country(ies) in which the Vendor does business by signing the VMCC as a form of self-certification. Additionally, PLBY conducts a conflict minerals survey each year to further verify the ethical sourcing practices of Vendors.
- Employee Training and Accountability
Those PLBY employees or authorized agents who have responsibility for supply chain management or operations, or are involved with quality assurance in connection with PLBY’s purchase of products, are required to be familiar with PLBY’s Code of Conduct, PLBY’s Supply Chain Incident Response Plan, and other policies (such as PLBY’s Code of Business Ethics). PLBY conducts on-going trainings and communicates key updates regarding human trafficking and slavery issues within product supply chains to its applicable business divisions. Any employees or authorized agents who do not adhere to these PLBY policies may face disciplinary action including termination of their employment or contractor engagement with PLBY, as applicable.