California Transparency in Supply Chains Act of 2010
Linari Beauty requires all vendors who wish to conduct business with Linari Beauty to sign a binding Vendor Purchasing Agreement that denotes acceptance of all terms and conditions within such agreement. Under the Vendor Purchasing Agreement, vendors must comply with all applicable U.S. and foreign laws, rules and regulations. Similarly, all Linari Beauty manufacturers must execute a Manufacturing/Formulation Agreement that requires compliance with all U.S. and foreign laws, rules and regulations. This includes any and all laws and regulations, domestic and foreign, that pertain to human trafficking and forced labor. Linari Beauty also requires all private label vendors to certify that they are in compliance with the laws regarding slavery and human trafficking in the countries in which they do business.
Audits
Linari Beauty reserves the right under its Manufacturing/Formulation Agreement to audit the facilities of its vendors that are used in the manufacturing, receiving, sampling, analyzing, storing, handling, packaging and shipping of products ordered by Linari Beauty. A purpose of these audits would be to assure good manufacturing practices and compliance with applicable laws and regulations at these facilities.
Internal Accountability
Vendors are held accountable for non-compliance with Linari Beauty's Manufacturing/Formulation Agreement and Vendor Purchasing Agreement. Vendors subject to the Manufacturing/Formulation Agreement are required to provide Linari Beauty a written response to any audit observations Linari Beauty's auditors issue to the vendors, and are to immediately implement any corrective actions or enhancements to their manufacturing, packaging and labeling operations and processes, as requested by Linari Beauty.
If Linari Beauty discovers that a vendor is not in compliance with the expected ethical standards, which include the elimination of human trafficking and forced labor within its supply chain, Linari Beauty will provide such supplier with the opportunity to remedy any potential non-compliance through the implementation of a corrective action plan. If the supplier fails to remedy the non-compliance, Linari Beauty reserves the right to eliminate such vendor from its supply chain. Linari Beauty employees are held accountable for non-compliance with Linari Beauty's Code of Business Conduct. In accordance with the code, any employee who is aware of a violation or suspected violation of the code, will refer the violation to the Senior Vice President of Human Resources or the Ethics Hotline. Violations of the code are addressed promptly by Linari Beauty, subject to compliance with applicable laws or regulations, and may subject persons to corrective and/or disciplinary action, including termination of employment.
Training
Linari Beauty recently launched an employee training program. Included in the program is a training module on ethics, which includes social responsibility topics.
Conclusion
Linari Beauty will not tolerate any instances of human trafficking or other forced labor within its supply chains. Linari Beauty expects that its employees, directors, suppliers and service providers conduct all relationships in accordance with the highest ethical standards. Failure to comply with Linari Beauty's standards will result in appropriate actions being taken against such individuals and companies to preserve Linari Beauty's high standards of business conduct.
