STATEMENT FOR THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB 657)


Global Brands Group Holding Ltd. ("GBG" or the "Company") is committed to legal compliance and ethical busi-ness practices in all of our operations worldwide. We choose suppliers and contractors who we believe share that commitment.

GBG takes the risks of slavery and human trafficking in our supply chain very seriously. Like many companies manufacturing or selling products in California, we are required to comply with the California Transparency in Supply Chains Act of 2010 (California Senate Bill 657). The law was designed to increase the amount of informa-tion available to consumers about the efforts of manufacturers and retailers to eliminate the risk of modern day slavery, forced labor, human trafficking and similar human rights violations ("slavery and human trafficking") from their supply chain. Accordingly, below are some examples of how GBG is working to eliminate that risk from our supply chain.


  1. RISK ASSESSMENT. The Company internally assesses the risk of slavery and human trafficking with respect to the supply chain for all of its products. To judge which of its sourcing countries presents the highest risk levels, the Company utilizes several publicly available governmental and intergovernmental resources. The Company continuously assesses its risk as these resources are updated and as new, credible resources become available.
  2. AUDITS. The Company conducts audits of its direct suppliers to evaluate compliance with the Company's Global Supplier Principles, which include standards for slavery and human trafficking in the supply chain. We utilize unaffiliated third party workplace compliance audit firms and our agent representatives to conduct both announced and unannounced factory audits on our behalf. In addition, GBG is also a signatory to the global buyer principles of the International Labor Organization (ILO)'s Better Work program and relies upon indepen-dent Better Work factory assessments in lieu of our own inspections in countries where Better Work operates. Current GBG sourcing countries with active Better Work programs include Cambodia, Haiti, Nicaragua and Vietnam. The Company also supports ongoing supplier improvements through training and technical assistance.
  3. SUPPLIER CERTIFICATION. The Company requires that all suppliers comply with applicable laws within their country of business regarding slavery and human trafficking. All GBG suppliers are required to adhere to the GBG Code of Conduct which, among other things, prohibits child labor and any form of forced, bonded, trafficked, indentured or prison labor, and requires compliance with applicable laws and regulations regarding health and safety in working conditions.
  4. ACCOUNTABILITY STANDARDS AND PROCEDURES. GBG maintains strong internal accountability proce-dures, which are communicated through our Code of Conduct and Business Ethics. All Company employees and agents with production, sourcing or quality control responsibilities, as well as internal buying offices and trading companies doing business with the Company, are provided with copies of the Company"s Global Sup-plier Principles. In the case of non-compliance, the Company examines the specific situation and develops an appropriate strategy for resolution. GBG associates who regularly visit suppliers are also asked to assess conditions informally while on location and report back any concerns, and GBG Compliance and Production teams meet regularly to review supplier performance on social compliance and discuss sourcing strategy.
  5. TRAINING. The Company provides internal training to its managers and employees with direct responsibility for supply chain management that specifically raises awareness of slavery and human trafficking and focuses on mitigating the risks within our supply chain. The Company encourages its agents, vendors and suppliers to participate in seminars and training programs on social compliance issues (including the issues of slavery and human trafficking) to further raise awareness of the issues and mitigate the risks within the Company's supply chain.