California Transparency in Supply Chain Act of 2010
The California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code 1714.43 and Cal. Rev. & Tax Code 19547.5) was designed to ensure that manufacturers and large retailers provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains, to educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains, and thereby, to improve the lives of victims of slavery and human trafficking.
Slavery and human trafficking are issues that Hot Tools takes very seriously. Our supply chain staff actively manage and oversee our supply chain to ensure that our corporate responsibility standards are upheld.
Hot Tools therefore makes the following disclosures pursuant to the California Transparency in Supply Chains Act:
- Hot Tools is committed to fair labor practices within our supply chain. While we do not implement a formal process to verify the entities in our supply chain, Hot Tools does require that its manufacturers and material suppliers certify that they will comply with our Supplier Code of Conduct, which prohibits slavery and human trafficking. Occasionally, Hot Tools will permit a manufacturer to certify that it will comply with its own code of conduct instead of Hot Tools’ Supplier Code of Conduct, provided the manufacturer’s code of conduct is at least as stringent as Hot Tools’ Supplier Code of Conduct when it comes to issues of slavery and human trafficking.
- Hot Tools requires all manufacturers and material suppliers with which it orders product beyond a de minimis amount (as reviewed annually based on Hot Tools’ overall orders) to participate in an initial social compliance audit. All manufacturers located outside the U.S. are subject to an annual third-party independent audit while U.S.-located manufacturers and suppliers may be subject to a biennial audit conducted by Hot Tools personnel or by a third-party auditor. Hot Tools does allow its manufacturers and material suppliers to provide results from a third-party audit conducted for a customer other than Hot Tools if it meets certain standards for independence and completeness as established by Hot Tools. Hot Tools also conducts internal audits from time-to-time. Corrective action plans are created after each audit, whether independent or internal, and follow-up visits are conducted, as warranted, to monitor and ensure that corrective actions are taken. Evidence of slavery or human trafficking is a zero-tolerance violation, and Hot Tools would immediately move to terminate a manufacturer or material supplier if such evidence were found.
- Hot Tools requires its manufacturers and suppliers to certify that they will comply with all applicable labor regulations in the country in which they operate, as well as with Hot Tools’ Supplier Code of Conduct.
- Hot Tools’ supply chain employees undergo an annual training educating them on how to identify evidence of slavery and human trafficking. Employees are asked to report any violations to the Senior Vice President - Product and the Chief Legal Officer, which will then investigate and take all appropriate and necessary steps. Employees may also report such concerns anonymously through Hot Tools’ ethics hotline which is managed by an independent third-party and is available twenty-four hours a day.