California Transparency Act

GBG is committed to doing business with suppliers that respect the culture in which they operate, the local law, and the workers who manufacture our products. Because of this, GBG has developed our Workplace Code of Conduct, which sets forth requirements that all suppliers must meet in order to do business with GBG. In addition to the specific provisions in this Code, GBG expects its suppliers to act reasonably in all respects and to do their best to ensure that no abusive, exploitative or illegal conditions exist in their workplaces.

GBG requires all of its suppliers, including subcontractors and raw material suppliers, to accept announced and unannounced audits conducted by GBG and independent third parties to verify compliance with GBG’s Vendor Code of Conduct. Each supplier is required to sign GBG’s Vendor Code of Conduct. If any portion of the Code of Conduct is violated, GBG will require immediate resolution of the issue or termination of partnerships will occur for failure to comply.

To further insure consistent understanding of all Codes of Conduct all GBG employees directly involved in supply chain management will be provided with ongoing training on the below Code of Conduct including slavery, human trafficking, and child, forced, or prison labor.

Workplace Code of Conduct Country Law: GBG suppliers must operate in full compliance with the laws of their respective countries and with all other applicable laws, rules and regulations, including those relating to labor, worker health and safety, and the environment.Subcontracting: GBG will only work with subcontractors who comply with this Code and who have signed a copy of this Code. Supplier must agree to disclose to GBG the name and address of every subcontractor used in the production of GBG garments and products.Recordkeeping: Suppliers and subcontractors must agree to permit GBG and/or their representatives to inspect all facilities and documents to ensure compliance with local laws and international standards. All documents provided must be accurate and must be presented in a manner that allows for a complete inspection by auditors.Communication of Standards: GBG expects our suppliers to support and cooperate in the distribution of this code.

Wages and Benefits: Suppliers for GBG must pay all employees who manufacture GBG garments, products, or components at least the minimum wages and benefits mandated by local law, including an annual paid holiday as required by law or which meet the local industry standard. Wages must be paid directly to the worker in full in legal tender. Only legal deductions are permitted, and workers must be notified of these deductions. Payment of wages must be made at or near the workplace. Work Hours and Overtime: Suppliers for GBG must comply with legally mandated work hours and use overtime only when each employee is fully compensated according to local law. Each employee must be notified at the time of hiring if mandatory overtime is a condition of employment. Each employee must be provided, on a regularly scheduled basis, one day off in seven and require no more than 60 hours of work per week on a regular scheduled basis, or comply with local limits if they are lower. Child Labor: GBG suppliers shall employ workers who meet the applicable minimum legal age requirement of their country, or are at least 16 years of age, whichever is greater.

Forced Labor: GBG suppliers may use no forced labor, in any form, whether prison labor, indentured labor, bonded labor or otherwise.

Discrimination and Harassment: No employee of GBG suppliers shall be subject to unlawful workplace discrimination, harassment or abuse. Discrimination must not occur on the basis of race, color, sex, religion, political opinion, nationality, social origin, maternity or marital status. Health and Safety: The workplace must be safe and healthy, and suppliers must comply in all respects with all applicable laws regarding the provision of a safe, hygienic, and healthy working environment. Suppliers must take steps to prevent workplace injuries and illnesses, and must train employees to use safe workplace practices.Freedom of Association: Workers must be free to join associations of their own choosing. Suppliers must not interfere with workers who wish to lawfully and peacefully associate, organize, or bargain collectively. The supplier must not threaten, penalize, restrict or interfere with workers’ lawful efforts to join associations of their choosing. Environment: GBG will favor suppliers and contractors who take steps to ensure that their operations have the least impact possible on the environment. Monitoring and Verification: GBG, by our representatives, may audit the facilities of any supplier and the facilities of any subcontractor. All suppliers and subcontractors shall fully cooperate and provide access to all facilities and documents to ensure compliance with this Code. GBG reserves the right to perform unannounced audits when deemed appropriate.Customs Compliance: Our manufacturing partners must comply with applicable customs law and, and in particular, will establish and maintain programs to comply with customs laws regarding illegal transshipment of product.

Disclosure of GBG pursuant to California Transparency in Supply Chains Act (SB 657)

  1. GBG managers and/or a 3rd party auditor, depending on factory location, relationship history, and past compliance performance, will conduct audits to verify product supply chains including evaluating and addressing risks of human trafficking and slavery.
  2. These audits of suppliers will generally be announced and will evaluate suppliers’ compliance with GBG’s Code of Conduct for trafficking and slavery in supply chains. If GBG is given any reason to believe unacceptable conditions may exist, we will proceed immediately to unannounced audits, either by GBG staff or 3rd party auditors.
  3. GBG will require direct suppliers to certify that materials incorporated into the product also comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
  4. GBG will maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking and will act quickly to correct any improper actions.
  5. For employees who have direct responsibility for supply chain management, GBG will establish ongoing training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.