Supply Chain Standards and Responsibilities

Last Updated: December 15, 2014

At Justin Brands, Inc. we have a strong commitment to conducting business in a lawful and ethical manner, including engaging suppliers that are committed to the same principles. We require suppliers in our retail manufacturing supply chain to comply with our Supplier Code of Standards and Responsibilities, which is reprinted below. We track remediation closely, and conduct follow-up audits for all significant issues.

Justin Brands, Inc. warranties that the products, services, and fixtures it provides (a) will be fit for the intended purpose, free from defects in material and workmanship and merchantable,
(b) will have been designed, manufactured, labeled, packaged, sold, and delivered in strict compliance with the provisions of all applicable laws, rules, regulations, and codes, including all amendments thereto, including but not limited to the following: The Consumer Products Safety Act, the Consumer Product Safety Improvement Act of 2008, Flammable Fabrics Act, the Americans with Disabilities Act; Federal Food Drug and Cosmetics Act, California Transparency in Supply Chain Act of 2010, Child Safety Protection Act, Hazardous Substances Labeling Act, Federal Hazardous Substances Act, Poison Prevention Packaging Act, Textile Fiber Products Identification Act, Wool Products Labeling Act. Federal Trade Commission Act, Rules and Regulations, Fur Products Labeling Act, the Lacey Act; Customs Modernization Act, California Safe Drinking Water and Toxic Enforcement Act (also known as Proposition 65); all Federal Trade Commission Rules and Regulations; alll Department of Alcohol, Tobacco and Firearms Rules and Regulations, and the standards of Underwriters Laboratories, Inc. (including all language requirements) or such other testing laboratory approved by Justin Brands, Inc.,
(c) contains, if applicable, claims made by Vendors in any packaging, labeling, advertising, or other consumer material that are true and have been substantiated at the time such claims are made;
(d) will be in compliance in all respects with all specifications, performance standards, drawings, samples or descriptions furnished, specified or adopted by Justin Brands Inc.,
(e) will be in conformity with any samples provided by Vendors to Justin Brands, Inc., (f) will not violate the trademark, copyright, or patent rights or any other intellectual property rights of others; and
(g) will be free and clear of all liens, security interests or other encumbrances. Vendors must represent they are in compliance with the Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and any other applicable anticorruption laws or regulations and Vendors covenants that during the time of any Vendor agreement, Vendor remains in compliance with the Vendor Code of Conduct (below). Any disclaimer of these express warranties of any implied warranties of merchantability or fitness for a particular purpose, or their contractual obligations, or limitation of remedies for breach of warranties shall be ineffective. All remedies and warranties shall survive inspection, tests, acceptance and payment by Justin Brands, Inc.

Justin Brands, Inc. subscribes to and supports all U.S. Fish & Wildlife Rules & Regulations. Additionally, some states restrict the sale of products made with certain exotic leathers, i.e. some snake and elephant. In cases where a state restricts the sale of certain exotic leather products, products containing those materials will not be available in and will not be shipped to consumers residing in that state.

Supplier Code of Standards and Responsibilities

  • Guiding Principle
  • Our suppliers' business and labor practices must comply with all applicable laws of the countries in which they are doing business and with other applicable laws, as well as the requirements of this Code. Suppliers must comply with the standards of this Code even when this Code exceeds the requirements of applicable law.

  • Prevention of Child Labor
  • Justin Brands, Inc. will not tolerate the use of child labor. Our suppliers must employ workers whose age is the greater of 15; the age of completion of compulsory education; or the minimum age for employment in the country of manufacture. Furthermore, suppliers must comply with all local laws pertaining to the restrictions on workers under the age of 18, including restrictions on their exposure to situations in or outside of the workplace that are hazardous, unsafe or unhealthy. Justin Brands, Inc. supports the development of legitimate workplace apprenticeship programs that comply with applicable laws and this Code.

  • Prevention of Involuntary Labor
  • Employment must be voluntary and workers must be free to leave work and terminate their employment with reasonable notice. Our suppliers may not use forced labor - prison, indentured, bonded, or otherwise. Our suppliers may not require workers to surrender government issued identification, passports, or work permits as a condition of employment. Suppliers must ensure that any worker staffing or recruiting agencies comply with this Code and with the applicable laws of the supplier’s country and the worker’s home country, whichever is more stringent, in its protection of workers.

  • Antidiscrimination
  • Conditions of employment should be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Our suppliers may not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, age, political opinion, pregnancy, marital or family status, or similar factors in hiring and employment practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers may not subject workers or applicants to medical tests that could be used in a discriminatory manner.

  • Fair Treatment
  • All workers are to be treated with respect and dignity. Our suppliers may not engage in or permit physical or psychological coercion, including threats of violence, sexual harassment or abuse, verbal or physical abuse, or unreasonable restrictions on entering or exiting suppler facilities. Workers should be free to voice their concerns to Justin Brands, Inc., and allowed to participate in any Justin Brands, Inc. audit process, without fear of retaliation by factory management.

  • Immigration Law and Compliance
  • Our suppliers may employ or use only workers who have a legal right to work. If suppliers employ foreign or migrant workers, such workers must be employed in full compliance with the immigration and labor laws of the host country.

  • Wages & Benefits
  • Suppliers should realize that wages are essential to meeting their employees’ basic needs. Our suppliers must may their workers in the timely manner and by providing compensation including overtime pay and benefits that at a minimum satisfy applicable laws.

  • Working Hours
  • Except in unusual or emergency situations, employees’ workweek, including overtime, will be limited to 60 hours, and will include at least one day off for every seven-day work period. Working hours may not exceed the maximum amount permitted by law.

  • Freedom of Association
  • Our suppliers must respect the rights of employees to establish and join a legal organization of their own selection. Workers may not be penalized or subjected to harassment or intimidation for the non-violent exercise of their right to join or refrain from joining such legal organizations.

  • Safety & Health
  • Our suppliers must recognize that workers deserve a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below.

  • Occupational Safety
  • Suppliers must control worker exposure to potential physical safety hazards by installing physical guards, barriers and engineering controls. Where such controls are not available, suppliers must implement administrative controls and educate workers on safety procedures. In all cases, workers must have appropriate personal protective equipment for jobs that require exposure to hazardous working conditions. Suppliers must appropriately manage, track, and report occupational injuries and illnesses.

  • Emergency Preparedness and Response
  • Suppliers must identify emergency situations and implement response systems, including emergency reporting, alarm systems, worker training and drills, first-aid supplies, fire detection and suppression equipment, and unblocked exit facilities.

  • Machine Safeguarding
  • Suppliers must implement a regular machinery maintenance program. Production and other machinery are to be routinely evaluated for safety hazards.

  • Dormitories
  • Suppliers who provide residential facilities for their workers must provide clean and safe dormitories with emergency egresses, reasonable personal space, and entry and exit privileges.

  • Ethical Behavior
    • No Bribery
    • Our suppliers may not offer or accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our suppliers may not induce Justin Brands, Inc. employees to violate our Code of Business Conduct and Ethics.

    • Anti-Corruption
    • Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act, and not offer anything of value, either directly or indirectly, to any government official in order to obtain or retain business. Suppliers may not make illegal payments to government officials themselves or through a third party. Suppliers who are conducting business with the government officials of any country must follow Justin Brand Inc.’s guidance on the law governing payments and gifts to governmental officials.

    • Whistleblower Protections
    • Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers should create a mechanism for workers to submit their grievances anonymously.

    • Management Systems
    • Suppliers must adopt a management system to ensure compliance with applicable laws and this Code and to facilitate continual improvement.

    • Management Accountability and Responsibility:
    • Suppliers should have designated representatives responsible for implementing management systems and programs that oversee compliance with applicable laws as well as this Code. Senior management must routinely review and assesses the quality and efficiency of the management system. Justin Brands, Inc. also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Code.

    • Risk Management
    • Suppliers must establish a process to identify the environmental, health and safety and ethical risks associated with their labor practices. In addition, management should develop appropriate processes to control identified risks and ensure regulatory comapliance.

    • Training
    • Management must maintain appropriate training programs for managers and workers to implement the standards in this Code and to comply with applicable legal and regulatory requirements.

    • Communication and Worker Feedback
    • Suppliers must clearly and accurately communicate and educate workers about Justin Brands, Inc. policies, practices, and expectations. In addition, suppliers must implement a process to assess employees' understanding of the standards and practices covered by this Code. In addition, Justin Brands, Inc. may require suppliers to post the Code in a location accessible to their workers (translated into the appropriate local language).

    • Documentation and Records
    • Suppliers must create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements along with appropriate confidentiality to protect privacy.

    • Environment
    • Our suppliers must comply with applicable environmental laws. Justin Brands, Inc. encourages our suppliers to implement systems that are designed to minimize the impact on the environment by the supply chain system, the production process and the products themselves.

    • Environmental Permits and Recordkeeping
    • Suppliers must obtain and keep current all required environmental permits, approvals and registrations and follow the applicable operational and reporting requirements.

    • Effective Management and Disposal of Hazardous Substances:
    • Suppliers must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment. Workers require appropriate training on the safe-handling and disposal of hazardous substances. Suppliers must monitor and control wastewater or solid waste generated from operations before disposing in accordance with applicable laws. Finally, Suppliers must adhere to any required treatment of regulated air emissions before discharging in accordance with applicable laws.

    • Continuous Improvement
    • Justin Brands, Inc. encourages our suppliers to continuously improve and reduce waste. Justin Brands, Inc. welcomes suggestions and feedback from its suppliers to improve Justin Brands Inc.’s own operations and processes.

  • Corrective Action
  • Suppliers' compliance with this Code is subject to Justin Brands, Inc.’s review, including third-party auditing of production facilities and conducting confidential employee interviews. We require suppliers to take corrective actions for deviations from the Code, and Justin Brands, Inc. will track suppliers' remediation efforts. Justin Brands, Inc. may terminate its relationships with any supplier found to be in violation of the Code, including violation for denying access to Justin Brands, Inc.-approved auditors. Justin Brands, Inc. employees who manage our retail supply chain receive training on the Supplier Code of Standards and Responsibilities and Justin Brands, Inc.’s audit requirements. Justin Brands, Inc. also has a training program for our retail manufacturers on the Supplier Code and Justin Brands, Inc.’s supply chain standards. Our independent third-party auditor periodically conducts both unannounced and announced on-site audits of our retail manufacturers. Most of our retail manufacturers are audited before Justin Brands, Inc. will begin ordering products, and we expect all of our suppliers to meet the standards in the Supplier Code as a condition of doing business with us. Justin Brands, Inc.’s retail manufacturing purchasing agreements require our suppliers to comply with supply chain standards, which, among other things, include laws regarding slavery and human trafficking. Justin Brands, Inc. employees are subject to internal accountability standards, which include disciplinary measures up to and including termination, for failing to follow Justin Brands, Inc. requirements regarding our audits.