California Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act (Senate Bill 657) (the “Act”) was enacted by California in 2010. According to California Civil Code § 1714.43, the Act requires certain retail sellers and manufacturers doing business in California to disclose their “efforts to eradicate slavery and human trafficking from [their] direct supply chain[s] for tangible goods offered for sale.” Pine & South LLC (“Company”) is committed to act ethically and with high standards of conduct in the course of conducting its business. Company makes the following disclosures in accordance with the Act.

Verification

With respect to verification of product supply chains, we do not conduct annual assessments of our product suppliers to verify that they are not at risk for violating anti-slavery and human trafficking laws. We similarly do not use third-party verifiers in this regard. Our risk-management team is currently unable to verify whether our subcontractors use labor brokers. Company does not knowingly do business with any product supplier or subcontractor who engages in or otherwise supports slavery or human trafficking.

Auditing

In regards to audits of our suppliers, we do not monitor supplier behavior or conduct investigations of our suppliers at this time.

Certification

With respect to requiring our direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the countries in which they do business, currently, we do not require our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business. To the extent, however, that Company may require in a contract that a direct supplier comply with applicable law in the performance of the direct supplier’s obligations to Company, then such contractual obligation to comply with applicable law may cover laws regarding slavery and human trafficking.

Internal Accountability

With respect to the Company’s internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking, we do not currently employ internal accountability standards and procedures for employees and contractors failing to meet our company standards regarding slavery and trafficking.

Training

Regarding the extent to which Company provides our employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, Company does not provide employees or contractors with training on human trafficking and slavery.

For more information, please contact us at [email protected].

Last Updated October 2020.