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California Transparency in Supply Chains Act of 2010

AQUA LUNG AMERICA's response to The California Transparency in Supply Chains Act of 2010:

Number 1: Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

AQUA LUNG AMERICA systematically reviews, evaluates and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. This specifically includes a review of the risk of human trafficking and slavery.

AQUA LUNG AMERICA is very serious about establishing new vendor relationships. The first priority is to manufacture products by a group owned company. As a result - the employees working at these group owned companies are employed directly by AQUA LUNG AMERICA or one of our affiliated and related Aqua Lung Companies in Europe or Mexico. These are not contractors or sub-contractors and we can certainly guarantee that there is no human trafficking or slavery occurring at any one of our company owned facilities - over which we have total control and which are regularly audited by both us and our parent corporation and have strict compliance with all appropriate local and national regulations in the United States, Europe and Mexico respectively.

We do also purchase products from unrelated companies - the bulk of which have been supplying our company for many years and whom we know very well through regular personal contact, personal visits and also - based on the volume and type of relationship: independent audits

Occasionally, the need for a new supplier is required. When considering a new supplier, AQUA LUNG AMERICA will review the company and its respective country for political stability and port safety, AQUA LUNG AMERICA employee safety and travel, and other factors. At the factory level, AQUA LUNG AMERICA assesses the workforce profile, the manufacturing processes and the associated health and safety risks. Depending on the anticipated volume, third-party monitors may conduct audits. We continue to assess many supplier factories depending on the volume of purchases on a regularly scheduled basis. The audit process involves both announced and unannounced audits; observation and walk-throughs of each factory and related facilities such as dormitories; and interviews of a percentage of the workforce, both on the factory floor and in private interviews outside of factory grounds.

The audit standard employed is suggested and updated by several of our major customers including but not limited to Costco, Wal-Mart and Sears/Kmart and it specifically addresses the prohibition of human trafficking and/or slave labor.

Currently AQUA LUNG AMERICA does not audit or monitor factories producing raw goods for AQUA LUNG AMERICA merchant vendors. These products are predominantly raw goods in the form of raw plastics and glass and are mostly supplied by world renowned chemical companies.

It is AQUA LUNG America's expectation that every vendor who supplies AQUA LUNG AMERICA will monitor their own sourcing processes to ensure that they meet or exceed the standards established for them directly by AQUA LUNG AMERICA.

 

Number 2: Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

Currently, AQUA LUNG AMERICA audits a percentage of our large volume supplier's sites per year. AQUA LUNG AMERICA may select third-party service providers that utilize progressive methods for detecting noncompliance with appropriate documented Codes of Conduct (depending on the audit request source). While some audits are announced, AQUA LUNG AMERICA conducts unannounced audits as well. When a supplier is asked to remediate a violation of the specific Code of Conduct, possible unannounced or announced audits enable AQUA LUNG AMERICA to confirm if remediation has occurred. We are in the process of reviewing our audit tools to help auditors investigate potential incidences of human trafficking. We may strengthen the sections on recruitment, the use of labor intermediaries (agents or brokers) and on investigating the practice of human trafficking.

 

Number 3: Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

AQUA LUNG AMERICA recognizes the importance of protecting the human rights of workers who produce the raw materials for our products - specifically as it relates to slavery and human trafficking. We are focusing on two efforts:

  • Developing measurement tools to uphold human rights throughout the supply chain, including the raw materials phase
  • Providing clear guidance to our suppliers on applicable human rights standards

AQUA LUNG AMERICA is working to develop an approach which drills down into our supply chain, tracking a product from the raw materials stage from the perspective of material content a well as social compliance.

AQUA LUNG AMERICA specifies that manufacturing partners must associate with suppliers that comply with legal requirements in any country in which their business is conducted. Vendors must maintain current sufficiently detailed records to substantiate their compliance with applicable regulations. These documents must be made available to AQUA LUNG AMERICA employees or anyone acting on behalf of AQUA LUNG AMERICA on request. Such documents should include: (i) Personnel files on each employee reflecting proof of age; (ii) Working hours and payroll records by employee; (iii) Local health and safety evaluations; (iv) Employee grievances and suggestions and employer responses; (v) Documentation of exemption from local law; (vi) Payroll records; (vii) Terms and conditions of employment.

 

Number 4: Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

AQUA LUNG AMERICA has a process in place in the event that we identify a potential violation of human rights. We have used our process to work with suppliers to remedy potential fair labor violations.

AQUA LUNG AMERICA considers fair labor practices an important part of human rights. AQUA LUNG America's approach to fair labor violations focuses on working with suppliers to remedy the violations, uphold workers' rights and improve the overall workplace environment.

In the event of a potential violation, AQUA LUNG AMERICA promptly addresses the issue with the supplier and sets expectations for how the situation is to be addressed, based on internationally recognized best practices and standards for fair labor compliance. Any potential violation is reported to the appropriate business line manager.

We then conduct unannounced or announced audits to confirm that the supplier has addressed and remedied the potential violation. If a supplier does not correct the violations, we are prepared to end the relationship with that supplier. AQUA LUNG AMERICA understands and appreciates the importance of eradicating slavery and human trafficking.

Internal accountability
AQUA LUNG AMERICA senior management team has direct involvement and accountability in supporting our commitment to human rights. In addition, the respective business line manager reviews the results of every supplier audit conducted by AQUA LUNG AMERICA.

 

Number 5: Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

Our Materials and Product Development teams and the Director of Operations have or will receive training on human trafficking and slavery issues. AQUA LUNG AMERICA will establish a training program on human trafficking and slavery issues for a broader audience. We will provide training for other company employees and management who have direct responsibility for our international supply chain.

AQUA LUNG AMERICA is committed to the process of upholding human rights as we conduct every aspect of our business. We will update this document to reflect our progress in preventing and addressing potential human rights violations in our supply chain, particularly in the areas of slavery and human trafficking.