California Transparency Act

The California Transparency in Supply Chains Act of 2010 requires many companies manufacturing or selling products in California to disclose their efforts to address the issues of slavery and human trafficking, thus allowing consumers to make more informed choices about the products they buy.

The Venasense Responsible Sourcing Program is made of the following components and underpinned by the goal of protecting and promoting healthy and sustainable working conditions as well as identifying and addressing modern slavery and human trafficking.

Transparency: Venasense expects our suppliers to be open and honest with us about their successes and challenges. We also expect transparency into their supply chains – providing us the names and locations of their sub-suppliers. Everyone that chooses to wear our products should know how Venasense is seeking to improve the lives of those that made it.

Contractual Obligations: Venasense only sources from a select number of strategic suppliers known to respect the laws of their country and the rights of workers. Venasense requires all new factories to certify, via our contracts and Code of Conduct, that materials they incorporate into our products comply with the laws relating to slavery and human trafficking of the countries in which they are doing business.

Onsite Assessment of Supplier Social Practices: Prior to Venasense placing any orders, all new factories must undergo an onsite assessment by a professional, independent third-party social assessment firm. These social assessments ensure suppliers meet our minimum expectations with regards to working conditions as specified in our Code of Conduct. Onsite social assessments, which may or may not be unannounced, must include confidential worker interviews, review of documentation and records, and visual inspection of safety conditions. Assessment focus is also influenced and informed by identified, material, and region-specific challenges to ensure the appropriate due diligence is undertaken. Ongoing and additional onsite assessment frequency is dictated by both country risk and past performance. Slavery and human trafficking are considered zero tolerance issues for Venasense. Discovery of any Zero Tolerance (ZT) issues will automatically result in a failed assessment, and therefore, Venasense will cease placing orders if the ZT violation(s) are not remedied in a responsible manner and under a rapid and agreed upon time frame.

Continuous Improvement: Venasense maintains oversight resources and procedures to ensure suppliers follow-up and improve any identified deficiencies in a realistic and timely manner, emphasizing the need for root-cause-analysis and management systems that ensure long term performance and accountability. In any case, remedial efforts are always verified.

Training: Venasense provides company employees 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.