California Transparency in Supply Chains Act SB 657

Our Commitment to Responsible Manufacturing

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will take effect in California. This law is designed to increase the amount of information that manufacturers and retailers provide about how they address slavery and human trafficking in their supply chains. This will enable consumers to make better, more informed choices about the products they buy and the companies they choose to support.

HBtowershop's products are manufactured in independent factories around the world, and it is our policy to work only with suppliers who share our commitment to socially responsible and ethical business practices, including protecting the rights and welfare of individuals, promoting equal opportunity, and respecting all laws and regulations that apply to apparel, related industries and the environment. We believe that workers in our factories have the right to free choice of employment, freedom of association and collective bargaining. Workers also have the right to be free from harassment and unlawful discrimination in the workplace. Each factory that produces HBtowershop products is required to meet these standards and to comply with all local labor laws and International Labor Organization conventions. Our Code of Conduct outlines our standards in the following areas.

* Forced labor (forced labor, debt bondage, slavery and human trafficking)
* Child labor
* Harassment and abuse
* Non-discrimination
* Freedom of association
* Wages and benefits
* Working hours/overtime
* Health and safety
* Environment
* Subcontracting
* Legal Requirements
Slavery and human trafficking can take many forms, including forced labor and child labor. HBtowershop prohibits our suppliers from using the disciplinary practices of forced labor, debt bondage, slavery, human trafficking, child labor and physical abuse. All individuals employed by our suppliers shall be guaranteed freedom of movement. Overtime should be voluntary and suppliers should conduct due diligence to prevent third parties, such as labor brokers or contractors, from recruiting or employing victims of trafficking, debt bondage or other types of exploitation. HBtowershop reserves the right to take any action necessary to protect its interests, including terminating business relationships with any supplier that does not respect this Code or comply with its legal obligations.

In accordance with our internal social compliance program and the California Transparency in Supply Chains Act of 2010, HBtowershop conducts a supplier assessment of all potential new suppliers in accordance with our Code of Conduct prior to entering into a business relationship with them. This approach includes an initial risk assessment and supplier assessment questionnaire and includes the following areas.

*HBtowershop Purchasing Agreement
*HBtowershop Code of Conduct
* HBtowershop Social Compliance Policy
* HBtowershop Supplier Handbook

* Supplier Profile Master W-9 Form
* U.S. Customs and Border Patrol 10+2 Security Filing Program
* 10+2 Template
* HBtowershop Self-Audit Tool
* Certificate of Conformity

Supplier Audits:

HBtowershop has a zero tolerance policy for the existence of forced and/or child labor and abusive disciplinary practices. If any zero tolerance items are identified during an audit, HBtowershop reserves the right to take any action necessary to protect its interests, including terminating business relationships with any supplier who does not respect our Code of Conduct or its legal obligations.

Supplier Agreements:

HBtowershop holds its direct suppliers contractually responsible for compliance with our policies, as detailed in the Purchasing Agreement and Social Compliance Policy. All contractors and the secondary suppliers they use must meet the same standards of responsible manufacturing. If remediation efforts fail, any violations will result in immediate termination of the direct supplier relationship.

Internal Training:

HBtowershop encourages its employees who are directly or indirectly responsible for supply chain management to obtain training on how to mitigate risks associated with worker rights, slavery and human trafficking. Such training includes, but is not limited to, participation in supply chain seminars and webinars provided by independent companies.

Internal Accountability:

HBtowershop reviews its Responsible Manufacturing Commitment annually to ensure that it complies with all state and federal laws regarding worker rights and forced or child labor, including the California Transparency in Supply Chains Act of 2010.


HBtowershop recognizes that fair labor practices are an important element of human rights and is committed to doing its part in eliminating slavery and human trafficking in accordance with the California Transparency in Supply Chains Act of 2010. We believe it is important to help improve global labor standards in the apparel and related industries, and to work only with partners who share our beliefs. This document will be reviewed annually and updated with any new or changed procedures for our social compliance program.