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California Transparency in Supply Chains Act Disclosure

This disclosure is made in accordance with the California Transparency in Supply Chains Act (SB 567) which requires that companies disclose certain matters with respect to their efforts to ensure that their supply chains are free from slavery and human trafficking.

Tvilum have a longstanding commitment to the ethical and responsible sourcing of goods and supplies. This is also supported by our membership of the UN Global Compact.
Our Supplier Business Practices formalizes that commitment by requiring, among other things, that our suppliers respect our standards and those of our customers, including with regard to compliance with laws, human rights, child labor, human trafficking, slavery, wages and benefits, excessive working hours, corporal punishment, discrimination, safe and clean workplaces and other labor and employment standards.

Verification of supply chains and auditing of suppliers to evaluate supplier compliance and address risks with respect to human trafficking and slavery.

Tvilum have a formal system for reviewing and accepting new vendors. For vendors located in countries with a corruption perception index less than 40 according to http://www.transparency.org, this program requires a physical review of each new factory to ensure that it meets at least baseline requirements with respect to applicable laws and working conditions, including laws against human trafficking and slavery. Additionally, our Purchase Order Terms and requires compliance with applicable laws as well as the standards and requirements set forth in our Supplier Business Practices.

In addition to the process for selecting new vendors described above, Tvilum engages in verification of the practices of its existing supplier base (suppliers located in countries with a corruption perception index less than 40, according to http://www.transparency.org) through periodic announced audits to assess risks and ensure compliance with applicable laws and conditions, including laws governing human trafficking and slavery. These audits are conducted by third parties. If significant issues are raised by an audit, we may also conduct a follow-up unannounced audit to address the initial findings.

Tvilum maintains an internal scoring system with respect to its periodic audits of suppliers and records the results. Tvilum take appropriate action to help ensure that our Supplier Business Practice standards and applicable laws are observed.

Certifications from suppliers that materials incorporated into Tvilum products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Tvilum selection and continued use of suppliers is based on the following standards with respect to all goods that we purchase.

  1. Comply with all applicable laws and regulations.
  2. Protect against the use of workers younger than the minimum age required by law.
  3. Protect against the use of forced labor (i.e., human trafficking and slavery).
  4. Provide appropriate wages and benefits as required by law.
  5. Protect against excessive working hours that exceed local laws or business customs.
  6. Protect against physical and mental punishment of workers.
  7. Protect against unlawful discrimination against workers and encourage employment based on ability.
  8. Respect workers' rights to associate freely.
  9. Maintain safe and clean workplaces, including any residential facilities, in compliance with the law.
  10. Protect our confidential and proprietary information.

We will not knowingly work with suppliers that do not respect these standards and those of our customers. We will periodically assess our supplier's compliance with these standards and those of our customers. Any reported non-compliance will be investigated and appropriate action will be taken. These standards apply whether the supplier is to Tvilum or an affiliate or a third party.

Tvilum internal accountability standards and procedures for employees or contractors failing to meet company standards regarding trafficking and human slavery and training for employees and management who have direct responsibility for supply chain management.

Tvilum maintains internal accountability standards for employees through its legal and ethical compliance program ("Code of Business Ethics"), which focuses on areas of ethical risk, and helps foster Tvilum culture of honesty, accountability and transparency. Further, our Supplier Business Practices pledges: that Tvilum will avoid working with suppliers that do not respect our standards and those of our customers. If an employee is in violation of our Code of Business Ethics or if a supplier is acting in violation of our Supplier Business Practices, we will (in certain egregious situations) terminate such employee or supplier, or we will work with them to remedy the violation. If the effort to remedy the violation is unsuccessful, we will evaluate our business relationship with that supplier or employee and take appropriate corrective action. Corrective action may include cancelation of an affected order, prohibition on further use of a facility or supplier, termination of employment and reporting the violation to the proper authorities. If a supplier refuses access to our auditors, the relationship with that supplier will be terminated.

Tvilum believes that education and training are critical components to ensuring that our standards are met and that human rights within our supply chain are respected. All salaried employees, including those with responsibility for supply chain, are required to certify their compliance with our Code of Conduct. Tvilum Code of Conduct includes the requirement to comply with all laws in all places where Tvilum does business, and a violation of the Code may result in penalties, including termination.