California Transparency in Supply Chains Act of 2010
Zale Jewelers expects its business suppliers to comply with the applicable laws and regulations of the United States and those of the respective country of manufacture or exportation. Per the California Transparency in Supply Chains Act of 2010 (SB 657), below consumers will find a disclosure of the efforts Zale Jewelers is taking to address slavery and human trafficking in its direct supply chain. Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery: ** Zale Jewelers conducts risk assessments of its significant suppliers in its effort to evaluate and address risks of human trafficking and slavery. These risk assessments are conducted by independent external third parties. If potential risks are identified, a course of action is determined to best address them. ** Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains. Many of Zale Jewelers' largest suppliers are certified members of the Responsible Jewellery Council (RJC), as Zale Jewelers encourages all its suppliers to be. Suppliers that are certified RJC members receive scheduled audits by independent third party firms as part of a rigorous and fulsome RJC Code of Practices certification process. Significant suppliers that are not certified members of RJC are audited by independent third party firms that conduct audits that, while announced, are only announced with sufficient advance notice to permit access. In addition, for all suppliers, Purchase Order Terms and Conditions include statements regarding compliance with all laws. By agreeing to these terms and conditions, our suppliers confirm their understanding and agreement to these compliance standards. ** Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. ** Zale Jewelers' suppliers are asked to agree to adhere to the respective laws regarding human trafficking and slavery. ** Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. ** Zale Jewelers expects all employees to adhere to and comply with all laws which would include such laws related to human trafficking and slavery. Management is responsible for ensuring that all employees are aware of and adhere to a code of conduct which includes compliance with all laws. Any known incidences where an employee does not do so, appropriate disciplinary action is taken. Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.