The California Transparency in Supply Chains Act of 2010 (SB 657) ("Act") became effective January 1, 2012 in the State of California. The Act requires that certain companies doing business in California disclose their efforts to eliminate slavery and human trafficking from their direct supply chains. Kirkland’s fully supports California’s efforts to protect human rights and enforce ethical labor practices.
Kirkland’s is firmly committed to holding itself and its suppliers to the highest legal and ethical standards and Kirkland’s policies covering its suppliers demand that its suppliers do not engage in unethical business practices, including human trafficking and slavery. At this time, Kirkland’s does not have a formal verification program in place to ascertain compliance with such policies.
Kirkland’s does not currently provide specific training on mitigating the risks of human trafficking and slavery to its employees or impose formal standards or procedures prohibiting slavery and human trafficking, but if it becomes aware of a supplier or employee who is acting unethically with respect to human trafficking or slavery in Kirkland’s supply chains, Kirkland’s will take appropriate measures to address the situation.
In August 2012, in an effort to reduce trade in certain minerals and metals that have been used in finance or benefit armed groups committing violent acts in the Democratic Republic of the Congo, the U.S. Securities & Exchange Commission (SEC) adopted a final rule requiring all publically traded companies to disclose and report on the presence of specific “conflict minerals” in products they manufacture or contract to manufacture. (A copy of this rule can be found at https://www.gpo.gov/fdsys/pkg/FR-2012-09-12/pdf/2012-21153.pdf) Under this rule, conflict minerals are defined as tantalum, tin, tungsten, and gold.
Kirkland’s is committed to full compliance with the SEC’s Conflict Minerals rule and the ethical sourcing of all of our products. Our goal is to work with our suppliers to determine that all products we manufacture or contract to manufacture are “conflict free”, that is, that they either do not contain tin, tantalum, tungsten, or gold, or if they do, that these metals come from non-conflict sources, as identified in the SEC’s Conflict Mineral rule. While recognizing that the global supply chain tracing of these materials is complex, Kirkland’s will continue to evaluate and improve its process for ensuring that its products are “conflict free”.