CA Transparency in Supply Chains Statement
Our Continuing Commitment
Sariana LLC is committed to ethical and responsible conduct in all of our operations, respect for the rights of all individuals, and respect for the environment. We are dedicated to upholding the human rights of all workers involved in our product supply chains. We consider fair labor practices to be an important part of human rights. Our goal is to ensure that all individuals involved in our supply chains experience safe, fair and non-discriminatory working conditions. We will not knowingly work with any company that does not comply with our ethical standards.
This statement describes our actions to support human rights, including our efforts to guard against human trafficking and slave labor in our company’s supply chains, in compliance with the U.K. Modern Slavery Act and the California Transparency in Supply Chains Act.
Verification of Product Supply Chains
Our products come from partners all over the world, including buying agents, suppliers and manufacturers located in the United States and abroad. We require our suppliers to agree to comply with our Supplier Code of Conduct. This policy guards against human trafficking, slave labor, and child labor, and helps to ensure fair working conditions at all facilities in our supply chains.
Audits Evaluating Supplier Compliance
We require that suppliers monitor and evaluate their compliance with our Supplier Code of Conduct, including through periodic audits. The audits occur in several ways:
Our suppliers conduct internal audits of their factories and facilities to ensure compliance with the standards in our Supplier Code of Conduct, including prohibitions on human trafficking, slave and forced labor, and child labor; fair labor standards; safe working conditions; anti-discrimination policies; and fair treatment of workers.
We may conduct our own audits or use a third party to conduct independent audits of supplier factories and facilities if issues arise that suggest closer monitoring is required.
Certifications of Compliance by Materials Suppliers
Our suppliers must certify compliance with our Supplier Code of Conduct both for themselves and for their materials suppliers and subcontractors.
Our suppliers also must also abide by our Purchase Order Terms and Conditions, which contain the express requirement and warranty that the supplier is in compliance with all current and later adopted laws of the countries in which they operate and the products are produced, including laws governing labor standards and working conditions, and prohibiting the use of human trafficking, slave and forced labor, and child labor.
Internal Accountability Standards and Procedures
We recognize that we must hold our suppliers accountable for compliance with human rights standards, including our strict prohibition on forced labor of any kind. Our partners must monitor, report and verify compliance for themselves and their suppliers.
Suppliers must adopt or establish a management system designed to ensure compliance with this Code of Conduct and applicable laws and regulations; identify and mitigate related operational risks, and facilitate continuous improvement. The management system must include:
- Identification of company representatives responsible for ensuring compliance with the Supplier Code of Conduct;
- procedures for identification and mitigation of labor, human rights, health and safety, business ethics, environmental, and legal compliance risks;
- written standards, compliance objectives, implementation plans, and a periodic assessment of the supplier’s performance;
- as stated above, periodic self-evaluations and audits;
- procedures for documenting and maintaining records of compliance, and any violations; and
- a process for timely correction of any violations or deficiencies identified.
Any violation of our Supplier Code of Conduct, including potential human rights violations, must be reported to Sariana’s senior management and evaluated for appropriate and timely corrective action. We treat every violation of our Supplier Code of Conduct seriously, and reserve the right to terminate our relationship with any supplier who fails to meet our standards.
Training on Identifying and Eradicating Human Rights Violations
We are developing a training program for buyers, sourcing and quality control teams, senior management, and other employees with responsibilities in the supply chain, educating them about identification and eradication of human rights violations such as human trafficking, slavery and forced labor, and child labor.
As part of the management system described above, suppliers must provide training on identification and mitigation of compliance risks, including human rights violations such as human trafficking, forced labor and slavery, and child labor.
We are developing our own training program for senior management, buyers, sourcing and quality control teams, and other employees with responsibilities in our supply chains. This training will be repeated at appropriate intervals to ensure that all new employees are educated about our Supplier Code of Conduct and the issues relating to human rights violations.
We are committed to upholding the human rights of all workers involved in our product supply chains, and to the eradication of human trafficking, slavery and forced labor, and child labor worldwide.