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Transparency in Supply Chain Statement

prAna’s response to the California Transparency in Supply Chains Act (SB 657)

prAna’s sustainability policies explicitly prohibit human trafficking and slavery. Our policies, procedures, and operations are also designed to address many other social and environmental sustainability issues.

In 2010, California enacted the California Transparency in Supply Chains Act (SB 657, enacted as Civil Code section 1714.43), which requires that “every retail seller and manufacturer doing business in this state and having annual worldwide gross receipts that exceed one hundred million dollars ($100,000,000) shall disclose…its efforts to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale.” This document is prAna’s response to this requirement and will disclose to what extent, if any, prAna does each of the following:

1) Engage in verification of supply chains to evaluate and address risks of human trafficking and slavery.

prAna regularly evaluates and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. The production, sourcing, development, and design staff is heavily involved in ongoing factory reviews, as well as new supplier sourcing, on all aspects of sustainability, including prohibiting human trafficking and slavery.

prAna is a member of the Fair Labor Association (FLA), a nonprofit organization dedicated to ending sweatshop conditions in factories worldwide. Since 1999, the FLA has helped improve the lives of thousands of workers around the globe. By bringing together multiple stakeholders, calling for greater accountability and transparency from manufacturers, factories, and others involved in global supply chains, and creating lasting solutions to exploitative labor practices, we are making steady progress toward fulfilling our mission: protecting workers’ rights and improving working conditions worldwide.

As a member of the FLA, prAna is able to tap into resources and people who have been working on issues of labor and human rights around the world. The area of social responsibility is incredibly complex and no brand alone can address problematic issues of lack of law or enforcement or cultural behaviors and practices around the world. So in collaboration with the more than x00 FLA constituents, prAna is able to be more successful in our efforts to improve working conditions where our products are made.

prAna screens potential suppliers based on their product capabilities and through a lens of social and environmental due diligence. Seeking to work with suppliers who share our values is one of the best ways that prAna can improve the sustainability of our supply chain. We hold our suppliers accountable in our contracts with them.

Additionally, prAna monitors our supply chain, assessing factories for their adherence to prAna’s Standards of Engagement. Based on these assessments, we work with the factory to develop a corrective action plan to create sustainable change.

2) Conduct audits of suppliers to evaluate supplier compliance with prAna’s standards for trafficking and slavery in supply chains.

prAna uses third party monitors for the bulk of our monitoring and requires that certain procedures be followed by those monitors and auditors.

Auditors must have a good understanding of the culture and context of the area where the assessment takes place. Therefore, prAna requires that auditors gather information from knowledgeable local sources and consult with human rights, labor, religious or other leading local institutions that are likely to have the trust of workers and knowledge of local conditions, such as research and news of issues pertaining to trends in modern day slavery and human trafficking within a region, industry or country.

prAna believes that workers need to be at the core of the auditing process. Auditors must pay special attention to ensure that adequate time is scheduled for worker interviews. We encourage both individual and group interviews and require that auditors be sensitive to worker reprisal for speaking with the auditor. Auditors MUST speak the local language of the workers. Monitors are expected to interview union members of various levels, worker committees, and other worker organizations as part of the audit process.

Secure communication channels are necessary to allow employees of contractors and suppliers to report to prAna noncompliance with the workplace standards without punishment or prejudice for doing so. To achieve this, monitors are to leave a business card with the employees that they are interviewing.

Prohibition of human trafficking and slavery are key components of our Standards of Engagement and these are reviewed in great detail during all audits. Specific questions related to human trafficking and slavery are included in prAna’s assessment tool.

3) Require suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country in which they are doing business.

prAna strictly condemns and prohibits any form of forced labor or slavery including human trafficking, prison labor, indentured labor, and bonded labor as stated in our Standards of Engagement. Our factory social responsibility audits specifically assess compliance to our Standards and detailed forced labor benchmarks. All forms of forced labor, slavery, and human trafficking are included in our “zero tolerance” policy.

All supply chain business partners involved in the manufacturing or finishing of prAna products are expected to uphold our no Forced Labor standard. To this end, all direct suppliers have been asked to sign a certification statement, in their contract with prAna, agreeing that they will make a concerted effort to ensure forced labor, slavery, and human trafficking are not occurring in their supply chain and that they will comply with all the standards set forth in prAna’s Standards of Engagement, the local law, and, where applicable, collective bargaining agreements.

4) Maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
prAna’s Standards of Engagement are based on the FLA’s Code of Conduct, which defines labor standards that aim to achieve decent and humane working conditions. The Code’s standards are based on International Labor Organization standards and internationally accepted good labor practices.
As a member of the FLA, prAna is expected to comply with all relevant and applicable laws and regulations of the country in which workers are employed and to implement the Code in their applicable facilities. When differences or conflicts in standards arise, prAna is expected to apply the highest standard.
prAna seeks business partners who adopt a proactive and integrated approach to social and environmental responsibility. Our expectation is that suppliers will be transparent and cooperative in working with prAna to address any issues as they arise. Suppliers will develop and implement action plans for continuous improvement and prAna staff will monitor progress.
We expect our business partners to operate work environments where the standards and practices specified in our Standards of Engagement are implemented.

Should we discover an instance of non-compliance with our Forced Labor standard prAna will execute its remediation process for zero-tolerance issues. This process includes a root cause analysis, development of a corrective action plan, and potential reductions in order volumes depending upon the supplier’s response to the issue.

5) Provides training on human trafficking and slavery for all company employees and management who have direct responsibility for supply chain management , particularly with respect to mitigating risks within the product supply chain.

prAna’s production, sourcing, development, and design staff have undergone Human Trafficking and Slavery awareness training. This training is provided to all new employees, and updated annually for supply chain staff who are heavily involved in ongoing factory reviews and new supplier sourcing, and will integrate this new information into their daily decision-making.

At prAna, we understand that accountability is key to demonstrating our authentic commitment to sustainability. prAna’s corporate policy for sustainability is reviewed regularly by our Board Of Directors and approved by our CEO. This policy has been communicated throughout the company and informs the work being carried out through our sustainability program.