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Transparency

california transparency act

KÜHL California Transparency in Supply Chains Act Disclosure Statement

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At KÜHL, we are committed to promoting safe, healthy, non-discriminatory working environments for everyone who produces our products. We prohibit forced labor, human trafficking, and modern slavery in all of its forms.

We conduct business in an ethical way and understand that the manufacturing and distribution of our products impact the environment, workforce, and community. Exploited labor can stem from cost-saving efforts, and KÜHL selects its manufacturers based on the quality of materials supplied, like-minded business practices, commitment to safe working conditions, and accountability.

For more information on KÜHL’s sustainable engagement in our supply chain, please review our sustainability page.

The California Transparency in Supply Chains Act was created in 2010 to “provide consumers with critical information about the efforts that companies are undertaking to prevent and root out human trafficking and slavery in their product supply chains.”1

KÜHL takes its obligations under this Act very seriously and has policies and procedures in place to comply with the obligations under the Act. This document gives insight into those practices.

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We hold our contracted factories accountable to the highest standards in fair labor practices. We have policies and procedures in place to identify, assess and manage the risks of human trafficking and slavery in our supply chain. Risk assessment is performed internally by our CSR team on a regular basis.

Each of our factories signs our Code of Conduct, which is in accordance with the International Labour Organization conventions, the United Nations' Universal Declaration of Human Rights and the UN's conventions on children's rights and the elimination of all forms of discrimination against women. KÜHL vendors must attain compliance with certain social and environmental standards.

audit

We regularly audit contracted factories and suppliers through both internal and external third-party audits to assess compliance with our requirements and local law. Audits are announced and unannounced and are conducted by trained compliance auditors. We inspect for wage and social compliance, evidence of health or safety concerns, forced labor, human trafficking, and modern slavery.

To receive an approval rating, a factory must not have any serious health, safety, or labor issues in its facility. A contracted factory’s breach of our contract agreement can result in KÜHL taking corrective action, including termination of the contract.

certification

Our standardization and certification processes arose to oppose injustices in labor laws, animal welfare, and environmental impact. We are clear that all contracted factories and facilities must be in full compliance with all applicable laws, rules, and regulations concerning forced labor, human trafficking, and modern slavery. We explicitly forbid the use of forced labor and prohibit discrimination of any kind in the workplace.

KÜHL pursues these credentials when they hold merit, logic, and applicability towards our operations.

internal accountability

All KÜHL associates, including employees, contractors and management, must be in compliance with the principles stated herein relating to human trafficking and forced labor, and those found in our Code of Conduct.

Violation of these principles can result in disciplinary action, including employment termination.

training

KÜHL associates, including employees, contractors and management, complete online and facilitator-led training on our Code of Conduct and sign an agreement to follow its principles, including those related to forced labor, human trafficking, and modern slavery. Violation of our Code of Conduct by one of our associates can result in disciplinary action, including termination of employment.

We welcome feedback on our disclosure statement. Please send feedback to [email protected]


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