California Transparency in Supply Chains Act
The Act
The California Transparency in Supply Chains Act of 2010 (the “Act”) requires certain retailers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their supply chains. HMRS Violent Drivers Club LLC, DBA Campsite204, along with other subsidiaries in the United States, provide this statement in compliance with the Act on behalf of HMRS Violent Drivers Club LLC. and its subsidiaries (the “Companies”).
The Companies are committed to the highest standards of lawful, honest, and ethical conduct in all business dealings. This commitment is reflected in various policies and practices that have been in effect for years. For example, the Companies’ Business Conduct Policy mandates that the Companies, their employees, and their business partners strictly observe laws and ethical standards in all operations and every geographical area where they do business.
Verification
The Companies purchase raw materials and supplies from suppliers in the United States and abroad. The Companies generally verify their supply chains by doing business with well-established, reputable suppliers who respect the legal requirements of their jurisdictions. These suppliers typically have formal business conduct policies, which the Companies review to ensure consistency with their own policies. While the Companies believe their suppliers do not engage in illegal slavery or human trafficking, they do not otherwise engage in formal verification of product supply chains to evaluate and address these risks. Verification efforts, when conducted, are not performed by a third party.
Audits
The Companies expect all suppliers to comply with applicable laws and engage in honest and ethical business conduct. The Companies will take immediate action if they find evidence that a supplier is involved in any illegal activity, including slavery or human trafficking. Except for the verification discussed above, the Companies do not conduct formal audits of their suppliers to evaluate compliance with the Companies’ standards regarding slavery and trafficking in supply chains.
Certifications
The Companies do business with reputable suppliers who, to their knowledge, comply with the legal requirements of their operating jurisdictions and typically have formal policies to ensure their business activities are conducted legally, honestly, and ethically. The Companies do not require direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the countries in which they do business.
Accountability
The Companies enforce policies that demand lawful, honest, and ethical conduct in all business dealings. This includes a Business Conduct Policy requiring compliance with all applicable laws, rules, and regulations of the United States and other jurisdictions where the Companies operate. Violations of these policies may result in disciplinary action, up to and including termination of employment, or other legal actions as appropriate.
Training
Apart from the accountability measures mentioned above, the Companies do not currently provide specific training on slavery and human trafficking to employees and management responsible for supply chain management, particularly with respect to mitigating risks within the supply chains of products.