California Transparency in Supply Chain Act

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.

COIM S.p.A. and its global subsidiaries, including COIM USA, Inc., are dedicated to conducting business in a lawful and ethical manner. We hold our suppliers to the same high standards. It is our expectation that they also conduct themselves in such a manner. We are committed to the prevention of slavery and human trafficking in our supply chain.

1. Verification and Auditing of Product Supply Chain

   During our initial supplier assessment, we require any potential supplier to confirm whether it is compliant with the standards of labor and ethical business practices, which, among other things, define requirements preventing child labor and forced or compulsory labor and ensure proper working hours and remuneration. This is typically completed as a paper survey and implemented in the contract language. We do onsite audits on an as-needed basis. Existing suppliers are subject to periodic re-audit through questionnaires and contract obligations.

2. Certifications

   Our supplier contracts require direct suppliers to certify that materials incorporated into their products comply with labor laws, including specifically those regarding slavery and human trafficking, in the country or countries in which they are doing business.

3. Accountability

   Suppliers that fail to meet our requirements for compliance with acceptable labor practices are subject to a corrective action process and re-audit. COIM USA may deny business where the supplier does not meet the corrective action plan.

   With respect to COIM USA’s employees, our employee handbook emphasizes that each employee has a responsibility to report violations of company policy or legal requirements.

4. Employee training

   COIM USA provides training for employees involved in the supplier verification process.  Training is required on an annual basis.