California Disclosures

Updated as of January 1, 2023

These California Disclosures are specifically intended for California residents who may be customers, or visitors to websites operated by AroundTheDirt.com. For California-specific disclosures relating to privacy of your personal information, please see our Privacy Policy.

California Proposition 65

The Safe Drinking Water and Toxic Enforcement Act of 1986, also referred to as Proposition 65, is a California initiative to address concerns regarding exposure to toxic chemicals. Proposition 65 requires warning labels on products that contains certain levels of the 600+ elements that the California Air Resources Board considers a carcinogen or a reproductive toxicant. These elements include lead, brass, PVC and a multitude of other everyday elements.

The general Proposition 65 notice is: WARNING: You have purchased an item that contains a chemical known to the state of California to cause cancer, birth defects or other reproductive harm.

California Transparency in Supply Chains Act

As required under the California Transparency Supply Chain Act, we are disclosing our efforts to mitigate the risk of slavery and human trafficking in our supply chain.

Verification

AROUND THE DIRT, LLC. is committed to fair labor practices throughout the supply chain. New and existing private brand contracted factories are regularly assessed against our Human Rights Policy which is based on International Labour Organization standards. Assessments are initiated based on geographic location, workplace history or previous audit record and other policy requirements. These audits are performed by AROUND THE DIRT Compliance Team members and also by third party verifiers. Results are reviewed by Compliance Managers, who assist factories in remediating issues identified during audits, share key performance data with internal business partners as appropriate, and also engage with industry and NGO stakeholders to identify strategic opportunities to improve working conditions. AROUND THE DIRT is a Better Work Buyer Partner (www.betterwork.org) and leverages the Better Work program to engage with key factories in countries where Better Work operates.

Auditing

Each year AROUND THE DIRT audits a significant percentage of our private brand contract factories to determine if they are in compliance with our standards, which in addition to requiring compliance with local laws on working hours, wages and health and safety concerns, also prohibit forced, slave or child labor. Audits are performed by AROUND THE DIRT Compliance Team members or third party verifiers and are semi-unannounced within a negotiated time frame. Annual and follow-up audit frequency is determined in accordance with our policy and is based in part on the level of risk and non-compliance determined by previous audit results.

Certification

As part of the supplier onboarding process, all vendors are required to certify that they conduct business in accordance with all applicable laws and regulations which include any existing laws on slavery and human trafficking in the country of manufacture. AROUND THE DIRT certifies private brand factories into various risk levels and active status categories. Detailed Corrective Action Plans are required within 14 days for any non-compliance with local law or our Human Rights Policy. Factories must exhibit continuous improvement, transparency, and management cooperation to ensure continued certification and business eligibility. Additional follow up audits are required until high risk issues are resolved. Lack of continuous improvement may result in termination of the business relationship. Factories that demonstrate low risk and strong management systems have opportunities to reduce the frequency of audits.

Internal Accountability

The Vice President of Global Compliance, who reports to the General Counsel, is responsible for overseeing the compliance and factory monitoring programs. The Vice President of Global Compliance works with the AROUND THE DIRT Compliance Team members to ensure that the Factory Compliance Policy is followed and with Product Development and Sourcing teams to integrate key performance data into the sourcing business process and to address high risk factories. In addition to requiring corrective actions and remediation of identified non-compliances, AROUND THE DIRT actively encourages factories to take ownership of compliance management and implement root cause/management systems based approaches to facilitate sustainable improvement. In addition to working with factory management, AROUND THE DIRT strategically communicates responsible sourcing guidelines to internal business partners and vendors and also provides "hotline" channels for workers that we engage during factory visits.

Training

AROUND THE DIRT provides annual training to relevant associates and business units on our Human Rights Policy and program requirements. Training is conducted with management level associates in roles related to sourcing, product development, quality assurance and who interact with or travel to factories and may be in the best position to identify issues. Training on responsible sourcing guidelines and program expectations is also conducted in annual meetings with vendors and factories.