California Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2012 requires us to post a disclosure on how we as a company are taking steps to continue to eliminate slavery and human trafficking in our supply chain.

Verification

Vionic verifies there is no forced labor or slavery in its supply chain by requiring all third party manufacturers to commit to social compliance at the factory level, and a third party certification process is used to verify factories are upholding their commitment. Vionic factories are required to maintain Worldwide Responsible Accredited Production (WRAP) compliance which includes both an initial certification and an ongoing re-certification process. The WRAP Principles include, but are not limited to, the prohibition of forced labor, child labor or human trafficking. Factories that demonstrate proper adoption, deployment and monitoring of all WRAP Principles receive certification. The certificate applies to an individual factory who must open themselves up to auditing to maintain compliance with all WRAP Principles.

Auditing

Professional third-party monitoring firms conduct WRAP specific audits on factories. The auditors must meet rigorous accreditation requirements themselves and must undergo a robust WRAP training, including periodic refresher training courses, to be able to conduct WRAP audits. All certified factories are subject to random, unannounced post-certification audits that can occur at any time and have no limit on how often they can be performed.

Certification

The WRAP Certification Program seeks to independently monitor and certify compliance with 12 WRAP production principles. These principles are based on the rule of law within each country and include the spirit or language of relevant International Labor organization conventions. The first nine principles cover child labor and forced labor, health and safety, harassment and abuse, discrimination, hours of work, compensation and benefits and freedom of association. A principle on environment serves to demonstrate the industry’s commitment to environmentally responsible business practices. The final two principles, on customs compliance and security, ensure that the shipment of goods complies with applicable customs laws, and that no non-manifested cargo is transported along with finished products.

Internal Accountability

Vionic uses an internal rating program to monitor third-party factory performance. The rating system requires Vionic’s review of social compliance metrics on a quarterly basis. Failure to be certified to our social compliance standard or failures in other metrics of performance will trigger actions to initiate and communicate an action plan to comply with Vionic’s required compliance program. The categories included in this internal rating system are metrics for pre-production sampling, inspections, testing, consumer satisfaction, and social compliance.

Training

The WRAP certification process requires periodic auditing by third-party individuals that undergo training and retraining on social compliance principles. In order to become an accredited auditor for WRAP, one must complete an intensive training course conducted by the WRAP organization and periodically attend refresher training courses to maintain accreditation.