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Transparency in Supply Chains

The California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code 1714.43 and Cal. Rev. Tax Code 19547.5) was designed to ensure that manufacturers and large retailers provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains, to educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains, and thereby, to improve the lives of victims of slavery and human trafficking.

Slavery and human trafficking are issues that TOMS has always taken very seriously; we have a zero-tolerance policy towards these issues, as further described below. Our global supply chain staff actively manage and oversee our supply chain to ensure that our corporate responsibility standards are upheld.

TOMS therefore makes the following disclosures pursuant to the California Transparency in Supply Chains Act:

  • TOMS is committed to fair labor practices within our supply chain. While we do not implement a formal process to verify the entities in our supply chain, TOMS does require that all of its manufacturers and material suppliers certify that they will comply with our Supplier Code of Conduct, which prohibits slavery and human trafficking.
  • TOMS conducts annual audits of its manufacturers and material suppliers via a third-party independent auditor. All audits are conducted during a two-week window of which the manufacturer and material supplier are advised, though the manufacturer and material supplier do not know the precise date on which the audit will occur during that two-week window. TOMS also conducts internal audits from time to time. Corrective action plans are created after each audit, whether independent or internal, and follow-up visits are conducted to monitor and ensure that corrective actions are taken. Evidence of slavery or human trafficking is a zero-tolerance violation, and TOMS would immediately move to terminate a manufacturer or material supplier if such evidence was found.
  • TOMS requires its manufacturers and suppliers to certify that they, and any third parties from whom they purchase materials, will comply with all applicable labor regulations in the country in which they operate, as well as with TOMS' Supplier Code of Conduct and TOMS’ Code of Business Practices.
  • TOMS has put in place a Code of Business Practices that it expects all employees and contractors to comply with and which prohibits working with any suppliers that use any form of forced or trafficked labor, including slavery and human trafficking. Employees and contractors are asked to report any violation of this Code of Business Practices to TOMS’ Legal Department, which will then investigate and take any and all appropriate and necessary steps.
  • Although TOMS does not currently provide specialized training on slavery and human trafficking to its supply chain staff, we require that all employees comply with our policies, including our Code of Business Practices which mandates the prevention of slavery and human trafficking within our supply chain.

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