Disclosure under the California Transparency in Supply Chains Act and UK Modern Slavery Act
This Statement relates to our fiscal year ended December 31, 2016 (“Fiscal 2016”). This Statement describes the activities of Adrianna Papell LLC and its subsidiaries and affiliated companies (collectively, the “Company,” “we” or “our”). It is the Company’s policy to comply with all applicable laws relating to its supply chains and the Company has procedures in place to evaluate and address risks of human trafficking and slavery consistent with the California Transparency Act and the Modern Slavery Act of 2015. As part of periodic and routine audits of our third-party manufacturing contractors, suppliers and vendors (“Suppliers”) conducted by our agents, we verify compliance with Company standards against human trafficking and slavery in its supply chains as set forth in the Company’s Global Social Compliance Guide (“Compliance Guide”) and Code of Conduct. Adrianna Papell has confirmed with its Suppliers that materials incorporated into our products comply with applicable laws against slavery and human trafficking in the countries in which they are doing business. Our employees and business partners are aware of the appropriate action to take in the event that a supplier does not meet Company standards regarding slavery and trafficking, and ongoing educational efforts are conducted for Company employees and management who have direct responsibility for supply chain management.
The Adrianna Papell Group, is a leading women’s apparel company, founded in New York in 1979 and celebrates over 37 years of dressing women for all occasions. The Company has been focused on a single mission: “to make every woman feel beautiful”. With an artisanal attention to detail, the Adrianna Papell collections are best known for an elegance and flair that empowers women of all ages and silhouettes to feel their very best. The key to our success is strategically positioning ourselves as a brand that offers modern fashion at an affordable prices. The Adrianna Papell brand has a substantial market share in the dress business and is distributed to all leading retailers in the United States and has expanded its business across 27 countries, including the UK, through various channels and free standing stores globally.
Our products are manufactured to our specifications. We contract for the purchase of finished goods principally with independent third-party manufacturing contractors, whereby the manufacturing contractor is generally responsible for the entire manufacturing process. Most of our products are produced by third-party factories in Asia. We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and Suppliers and agents to comply with our values and our Code of Conduct.
Risks of Slavery and Human Trafficking in Supply Chain.
Due to the nature of our workforce and the locations of most of our employees, we believe that the risks of slavery and human trafficking in our own business are remote. While there are risks inherent with third-party manufacturing, we have established the Compliance Guide, Code of Conduct and other procedures to mitigate the risks of slavery and human trafficking in our supply chains for our products. Our approach is to focus on our direct Suppliers, since this is the level of the supply chain where we believe that we have the most influence and can therefore be the most effective.
Commitment to Ethics; Code of Conduct
We are committed to principles of ethical business practice and recognition of the dignity of others, including responsible labor practices. Our Compliance Guide and Code of Conduct are applicable to all of the Company’s Suppliers (including our third-party manufacturers, suppliers and vendors). The Code of Conduct expressly prohibits, among other things, the use of prison or forced labor or the acquisition of any materials used in any stage of the manufacturing of our products from a third-party that utilizes prison or forced labor. In addition, the Code of Conduct provides that our Suppliers must comply with all laws regulating local wages, work hours and benefits. We communicate the Compliance Guide and Code of Conduct initially as part of our Supplier onboarding process and, thereafter, periodically from time to time, including when there are updates. All of our Suppliers are required to certify compliance with the Code of Conduct. In the event of a violation of the Code of Conduct, we reserve the right to either terminate our relationship with the Supplier or to work with the supplier to implement corrective action to remedy the non-conformance.
Audits and Reviews.
All new Suppliers are approved after they pass our compliance and production requirements. We require engagement with one of our approved third party independent social compliance auditing agencies within one (1) year of initial orders. The production, buying and design team visit Suppliers on a regular basis to continue to build a strong working partnership. In most instances, where a deficiency is identified, corrective action is required on a specified timeline, followed by validation by the Company or its auditor that such deficiency has been remedied, including, if necessary through a re-audit of the manufacturer. In the case of a serious violation of the Code of Conduct, termination of the Company’s relationship with the manufacturer may occur, particularly where corrective action is either not possible or determined to be an insufficient remedy.
Internal Accountability and Training.
All production employees are required to undergo compliance and ethics training, including with respect to the Code of Conduct and the Compliance Guide.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year.
Customs Trade Partnership Against Terrorism (CTPAT)
Adrianna Papell, LLC is committed to a safe and secure supply chain by supporting the Customs Trade Partnership Against Terrorism (CTPAT), a voluntary United States Customs and Border Protection (CBP) business initiative designed to build cooperative relationships to strengthen the supply chain, border security and to continue the free flow of international trade. To this end, Adrianna Papell LLC received its CTPAT certification in 2008 from the CBP.
CTPAT was designed to achieve the highest level of cargo security through close cooperation between CBP and the principle stakeholders of the international supply chain such as importers, carriers, consolidators, licensed customs brokers, and manufacturers. CBP requests that businesses ensure the integrity of their security practices and communicate their security guidelines to their business partners within the supply chain.
CTPAT offers businesses an opportunity to play a major role in the war against terrorism and ensure a more secure supply chain for their employees, suppliers, and customers. Adrianna Papell LLC voluntarily joined this program to protect our supply chain and to promote safe and secure international traffic between our foreign suppliers and ourselves. Our supply chain partners include the foreign manufacturers of our products, the trucking companies that transport merchandise from the manufacturers to the overseas ports and airports, as well as the consolidators, freight forwarders and carriers that load, transport and ship our containers to our US destinations.
Adrianna Papell is proud member of the CPAT Program. We and our supply chain partners are committed to protect our supply chains from criminal activities such as illegal weapons and drug trafficking, terrorism, human smuggling, contraband, money laundering and cyber intrusions. Adrianna Papell LLC and our supply chain partners adhere to the CTPAT-mandated Minimum Security Criteria (MSC). All our employees, contractors, service providers and visitors are expected to comply with the CTPAT’s MSC as well as any policies, procedures, and instructions issued by Adrianna Papell.
ADRIANNA PAPELL, LLC
Adam Berkman, CEO, Adrianna Papell LLC