Social Compliance

California Transparency in Supply Chains Act Disclosure

California Transparency in Supply Chains Act Disclosure

World Market is committed to upholding the human rights of all workers involved in our product supply chains, and to guarding against the use of forced or slave labor in any manner.

Because we specialize in finding unique products from around the world and working with artisan communities in many countries, we are particularly committed to working with suppliers that abide by our standards, including our strict prohibition on the use of forced or slave labor. We will not knowingly work with any suppliers that violate this prohibition. This statement describes our efforts to guard against forced or slave labor in our company’s supply chains, in compliance with the California Transparency in Supply Chains Act of 2010.

World Market Code of Conduct

Each World Market supplier and buying agent must agree in writing to abide by our Code of Conduct, which is part of our Purchase Order Terms and Conditions and Vendor Guide. Our Code of Conduct prohibits the use of involuntary or slave labor, and also details our policies pertaining to non-discrimination, hiring and disciplinary practices, health and safety, environmental protection, wages and benefits, working hours, working and living conditions, employee relations, and other matters. Suppliers are expected to educate their employees about the standards and practices contained in the Code of Conduct. In addition, suppliers are responsible for providing the Code of Conduct to each of their suppliers and subcontractors and requiring that they abide by the standards and practices therein.

1. Verification of Product Supply Chains to Guard Against Human Trafficking and Forced/Slave Labor

When onboarding a new supplier, we check the supplier’s name and location against databases of suppliers suspected as engaging in forced labor, slavery or human trafficking.

All of our suppliers must provide written certification that they agree to abide by our Vendor Guide, which includes our Code of Conduct requiring compliance with the following:

• Suppliers must not use any forced, involuntary, bonded, indentured or slave labor, and must certify compliance with all labor laws of the country in which the goods are produced.

• Suppliers must be aware of indicators of forced or slave labor and actively address them. Procedures must be in place to consistently monitor for signs of trafficking and exploitation, particularly where the supplier’s business includes vulnerable populations such as migrants, women, and young people.

• Suppliers must comply with the child labor laws of the country where the workers are employed and of the exporting country, and no worker may be employed who is under 15 years old or younger than the age for mandatory compulsory education in the supplier’s jurisdiction, whichever is older. Suppliers must verify the age of their workers and maintain copies of their workers’ proof of age. Suppliers must follow all applicable laws and regulations regarding working hours and conditions for minors.

• Fair wages and benefits must be provided in compliance with the laws of the country of manufacture and export, including those relating to minimum wages, overtime, maximum hours, piece rates, benefits, and other elements of compensation.

• Overtime in excess of the hours allowed by the manufacturing country’s laws is prohibited, and employees may not work more than 60 hours in a week, except under extraordinary circumstances. Employees shall be entitled to no less than one day off in every seven-day period.

In addition, in compliance with the Customs Trade Partnership Against Terrorism (CTPAT), we annually prepare a Forced Labor Risk Assessment that provides risk-based mapping of our business, outlines our supply chains in their entirety, and includes regions and suppliers that pose the most risk, as well as certain measures we have taken to ensure that our supply chains are free from forced or slave labor.

2. Audits of Suppliers to Evaluate Compliance with Company Standards to Prevent Trafficking and Forced/Slave Labor in Supply Chains

We recognize that we must hold our suppliers accountable for compliance with our human rights standards, including our strict prohibition on forced or slave labor of any kind. We use a third party, Omega Compliance Group, to conduct independent third-party audits of some of our suppliers.

We have also created an online social compliance assessment and reporting system that addresses a variety of issues, including compliance with local labor laws, the prohibition on forced and slave labor, any use of minors in the workforce, wages and benefits, hours of work, health and safety, nondiscrimination, women’s rights, harassment, freedom of association, environmental practices, subcontracting, communication, and monitoring and compliance. All of our suppliers must either complete the social compliance assessment or provide us with a third-party audit report.

In many countries, we use buying agents who regularly interact with and visit the factories and other operations of local suppliers, and confirm that the suppliers with which they work comply with our Vendor Guide and Code of Conduct. These buying agents are aware of the indicators of forced or slave labor, and conduct periodic on-site visits in part for the purpose of inspecting working conditions and production practices.

Our own buyers may also periodically visit the factories of suppliers with whom they work directly, and have been trained to be aware of signs of forced or slave labor, and to report any observed issues or violations of our Code of Conduct.

3. Certification by Suppliers that Materials Used in Their Products Comply with Laws Regarding Forced Labor/Slavery and Human Trafficking

Our partners must verify, monitor and report compliance with our Code of Conduct for themselves and their suppliers. Our Code of Conduct expressly states that “[a]ll vendors’ operations, subcontractors’ operations, and all supply chain operations must procure all raw materials and/or components for products all the way up the supply chain solely from sources that do not utilize forced labor or engage in human trafficking.” Suppliers are responsible for providing the Code of Conduct to each of their suppliers and subcontractors and requiring that they abide by the standards and practices therein.

4. Internal Accountability Standards and Procedures to Ensure Compliance with Our Company Standards and Social Compliance Policy

Based on the results of the third-party audits and/or social compliance assessments discussed above, we will request remediation of suppliers as needed or possible suspension of further business. We have a written procedure in the event that any violations of our Code of Conduct are identified. In those instances, we work with our agents and suppliers to remediate any violations, and require that suppliers implement appropriate and timely corrective action. Any violation of our Code of Conduct that our agents, buyers or other employees become aware of must be reported and evaluated. We treat every violation of our Code of Conduct seriously, and reserve the right to terminate our relationship with any supplier who fails to meet our standards.

5. Training on Human Trafficking and Slavery for Employees and Management with Direct Responsibility for Supply Chain Management

We have adopted a CTPAT training program for buyers, sourcing and quality control teams, senior management and other employees with responsibilities in the supply chain that includes the identification and reporting of forced labor, slavery and human trafficking. This training will be conducted annually.