California Transparency in Supply Chains Act Disclosure Statement
The California Transparency in Supply Chains Act of 2010 (SB 657) (“Act”) became effective January 1, 2012 in the State of California. The Act requires that certain companies doing business in California disclose their efforts to eliminate slavery and human trafficking from their direct supply chains. Lenox Corporation (“Lenox”) fully supports California’s efforts to protect human rights and enforce ethical labor practices.
Lenox has programs to effectively manage the risks of slavery and trafficking in our supply chain.
Our Sourcing Code of Conduct (the “Supplier Code”) addresses business practices of our third-party suppliers. The Supplier Code, which must be agreed to and signed by each supplier before any Lenox purchase order can be processed, contains specific provisions prohibiting the use of child labor and forced or involuntary labor.
In addition to self-certification of compliance by each supplier, Lenox sourcing personnel are required to monitor supplier compliance.
Our purchase order agreements also contain representations that our suppliers are in compliance with all applicable federal, state and/or provincial, regional, municipal, and local laws, codes, regulations, rules, ordinances, decrees, permits, registrations and orders.
Moreover, Lenox may conduct, either on its own or through independent third-parties, unannounced visits and/or audits to ensure compliance with the Supplier Code.
The Lenox Compliance Hotline, available to all employees, directors and contractors, enables the reporting of any noncompliance by Lenox suppliers, their employees or subcontractors. Lenox employees who do not act promptly to report noncompliance matters may be subject to disciplinary action.