Supply Chain Transparency


DFS Group L.P. (“DFS”) abides by moral and ethical values in the management of the company. We expect our suppliers to respect and adhere to the same values. The California Transparency in Supply Chains Act of 2010 (the “Act”) requires retail sellers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. DFS makes the following disclosures under the Act: DFS has carefully verified its product supply chains, including the organization, reputation and institutional history of each of its suppliers, in order to achieve a high degree of confidence that the goods produced by those suppliers are not connected in any way with human trafficking and slavery. This verification was not conducted by a third party. All DFS suppliers are required to certify acceptance of the DFS Suppliers Code of Conduct, which prohibits, among other things, the use of forced labor and child labor by our suppliers. DFS does not conduct independent, unannounced audits of suppliers to evaluate supplier compliance with DFS standards to prevent trafficking and slavery in supply chains. However, DFS seeks assurances from its suppliers in regular face-to-face meetings that the suppliers do not use slavery and human trafficking to produce their goods. If any supplier fails to provide DFS with such assurances or if there are any circumstances giving DFS reason to suspect that such assurances are false, DFS will require independent confirmation via third party audit as a condition of continuing its business relationship with the supplier. DFS 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. DFS maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. DFS provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.