We at Helen Ficalora are committed to the protection and advancement of human rights.  As a company affected by the California Transparency in Supply Chains Act of 2010 (SB657), we are providing the following information about our efforts to evaluate and address any risks of human trafficking and slavery in our supply chain.
 

Verification.  We have various internal means by which we assess and evaluate the risks of human trafficking and slavery in our supply chains including (i) reviewing supplier profile information, (ii) conducting internal quality assessments, and/or (iii) engaging independent third parties to conduct risk assessments through inspections and site visits.

Audits.  We require suppliers to allow us and/or our agents to engage in certain monitoring activities to ensure that our suppliers comply with all applicable laws within their countries of operation and with our companies standards. These monitoring activities may include, but are not limited to, unannounced and announced site inspections, reviews of books and records, and interviews with employees.

Certification.  Suppliers who work with us must certify that they will comply with all applicable laws governing employment, wages, working conditions, benefits, and safety, in addition to all applicable environmental laws and regulations. Our commercial agreements with suppliers also include provisions specifically prohibiting practices associated with human trafficking and slavery.
 

Accountability.  Every one of our employees is expected to abide by our conduct policies, which requires them to act ethically and comply with all applicable laws. Any failure to comply with our conduct policies could lead to disciplinary actions. If we find any supplier, employee or contractor is not in compliance with company standards regarding human trafficking and slavery, we reserve the right to terminate our business relationship with them.

Training.  Although we currently do not conduct formal training for our employees about the responsibility for supply chain management, all such employees have significant experience in their positions and have conducted numerous inspections and site visits. All such employees should be aware of issues concerning human trafficking and slavery and are required to comply with company standards and all applicable laws.