Unique Vintage believes strongly in corporate responsibility and acting in compliance with applicable state, federal and international laws. In 2010, California passed the California Transparency in Supply Chains Act to help customers of large retailers and manufacturers identify whether those companies are making an effort to help eradicate slavery and human trafficking in their supply chains. Also in 2010, Congress passed the Dodd-Frank Act, which directs the Commission to issue rules requiring certain companies to disclose their use of conflict minerals if those minerals are "necessary to the functionality or production of a product" manufactured by those companies. Under the Act, those minerals include tantalum, tin, gold or tungsten. Finally, California's Proposition 65 requires businesses to provide warnings to Californians who use their products about the risk of significant exposure to chemicals that cause cancer, birth defects and other reproductive harm from the use of their products. At Unique Vintage, we strive to partner with manufacturers and suppliers whom we believe act in a responsible manner, including having no involvement with slavery, human trafficking, forced labor or child labor in violation of international standards. Although price is an important criterion in selecting such partners, we evaluate our partners on many other criteria, including business history, financial stability, quality of product, timeliness of delivery, working conditions, and compliance with applicable laws. We take the ongoing and tragic global condition of slavery and human trafficking, the exploitation and trade of conflict materials, and potential health risks to consumers very seriously. In order to do our part to eliminate these concerns, we have implemented important practices in the management of our manufacturing and supply chain. In the spirit of keeping our customers informed, we would like to describe the compliance program we recently adopted:
- Verification. Unique Vintage attempts to evaluate and address potential risks of human trafficking and slavery, the exploitation and trade of conflict materials, and the risk of exposure to chemicals prior to engaging with a manufacturer or supplier. At the beginning of a potential relationship, we inquire about a manufacturer or supplier's use of tantalum, tin, gold or tungsten sourced from the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (the "listed countries"). In addition, we use the US Department of Labor's Bureau of International Labor Affairs "List of Goods Produced by Child Labor or Forced Labor" online database (link below) to determine whether the manufacturer or supplier may carry a heightened threat of inhumane labor practices. We also use the California Environmental Protection Agency (the "CalEPA") database of chemicals known to cause cancer or birth defects to monitor the current status of certain chemicals under Proposition 65.
- Compliance with Laws. As part of our initial agreement with a manufacturer or supplier, we ask each of our manufacturers and suppliers to represent and warrant that they comply with (i) Section 1502 of the Dodd-Frank Act, (ii) Proposition 65, and (iii) all applicable laws regarding slavery and human trafficking of the United States and of the country or countries in which they do business. We ask our manufacturers and suppliers to also represent and warrant that they: refraining from, among other things, employing forced labor and child labor, prohibit harassment and discrimination in their workplace; allow for the free association of its workforce; provide safe and clean facilities; abide by all environmental, custom, and employment laws; and refrain from using conflict minerals. We also require our manufacturers and suppliers to update us if they use a chemical that is listed on the Proposition 65 list of chemicals known to cause cancer or other reproductive harm. In the event the manufacturer or supplier is unable to provide such certification, Unique Vintage will strive to assist the manufacturer or supplier with updating its practices in order to remedy the problem area. However, if the manufacturer or supplier is unable or unwilling to remedy the situation, Unique Vintage may seek to terminate the relationship.
- Internal Accountability. Unique Vintage has developed internal accountability standards and procedures for employees and contractors failing to meet our company standards regarding slavery and trafficking. If and when we uncover employee or contractor compliance problems, we provide written notice and a specified period of time to take corrective action. Further, we have designated an officer within the company to monitor internal compliance. Similar to a problem arising at the outset of our relationship, if a problem arises during the relationship with a manufacturer or supplier, Unique Vintage will strive to assist the manufacturer or supplier with updating its practices in order to remedy the problem area. However, if the manufacturer or supplier is unable or unwilling to remedy the situation, Unique Vintage may seek to terminate the relationship.