Legal Stuff

CA Transparency Act

INFORMATION ON MODERN SLAVERY AND HUMAN TRAFICKING
We are committed to continually improving our practices to ensure there is no slavery or human trafficking in our supply chain or in any part of our business. ILA takes its obligations under the Modern Slavery Act 2015 and the California Transparency in Supply Chains Act 2010 very seriously, and has a robust working practice in place in order to comply with such obligations. This policy document sets out those practices and gives insight into the supply chain and business processes of the company.

YOUR CONSUMER RIGHTS
California consumers have the right to request access to their personal data, additional details about our information practices and deletion of their personal data (subject to certain exceptions). California consumers also have the right to opt out of sales of personal data, if applicable.

ORGANIZATIONAL STRUCTURE AND SUPPLY CHAINS
Established in 2012, ILA is a designer, distributor and retailer of spiritual based apparel in the clothing industry. We have developed a distinctive corporate culture, and we have a mission to produce products which create transformational experiences for people to live happy, healthy, fun lives.

We offer a comprehensive line of apparel and accessories for women, men and children under the ILA brands. We do not manufacture our own apparel; instead, we work with 3 finished-goods suppliers in 6 countries and 7 raw material suppliers in 2 countries.We consider the greatest risk of modern slavery and human trafficking to exist in our supply chain as we do not manufacture our own apparel. A responsible supply chain starts with us and the decisions we make in selecting suppliers, and our ongoing procurement practices.

OUR POLICIES
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

Any concerns from any member of ILA employees regarding a likely risk of, or actual, breach of this policy are encouraged to report concerns to us via email at knockknock@internationallightworkersassociation.com or in person to any member of our partner sustainability teams.

RELEVANT POLICIES
In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies are relevant to ensuring that there is no slavery or human trafficking in any part of our business or our supply chains. Any form of forced labor, including but not limited to indentured and bonded labor, involuntary overtime, and prison is a zero tolerance violation. This applies to all suppliers, their employees and supply chains. This standard sets forth minimum requirements for the appropriate and ethical recruitment and management of foreign migrant workers, a group vulnerable to forced labor practices. It provides suppliers and their third-party labor brokers with clarity on these requirements. This applies to all suppliers with foreign migrant workers.

RISK ASSESSMENT AND DUE DILIGENCE
We assess, mitigate and avoid the risk of modern slavery and human trafficking within our own organization through the selection of values aligned suppliers, application of strict policies and procedures, targeted strategies, oversight built into our business operations, and the knowledge and skills of our employees.

ILA’s enterprise risk management (ERM) process helps to prioritize top risks across the business and ensure risks and mitigation approaches are presented to the Executive and Board. We assess risk based on a number of factors, including annual and ongoing risk reviews, supplier selection and industry collaboration.

• Identifying overarching geographical risk annually, we review four risk categories, refine risk criteria and evaluate thresholds. The risk categories are: (1) human rights issues, practices and legislation; (2) country level risk; (3) worker-type risk; and (4) process risk.

We use this information to update our processes and due diligence approach. On-the-ground findings from our teams trigger updates to our risk assessments.

• Supplier selection. Core to our approach is establishing long-term relationships with suppliers, which facilitates opportunities to identify, evaluate and address risk. We intentionally maintain a consolidated and curated supply chain and assess all new suppliers on financial and reputational risk and as well as human and labor rights practices.

We will only approve a supplier for onboarding if the required level of performance is achieved.

• Monitoring. We conduct assessments upon engagement of every new supplier and subsequently at least every 18 months (annually, for strategic suppliers and suppliers who operate in a high-risk context). In addition, we assess subcontractors that trigger specific risk categories, including the presence of foreign migrant workers.

Industry collaboration – We work with industry organizations, stakeholder groups and other brands to evaluate and address human rights and labor risks, including modern slavery, human trafficking and forced labor. For example, these processes helped us identify foreign migrant workers as a group particularly vulnerable to forced labor practices.

For additional information on our policies and practices toward eradicating modern slavery, human trafficking and forced labor in our supply chain, see ,please email us at knockknock@internationallightworkersassociation.com.