California Transparency in Supply Chains Act (SB 657)

Updated April 2025

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. Under the law, large manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s purpose is to educate consumers so they can make informed decisions.

At Clothing Shop Online (“CSO,” the “Company,” “we,” “us,” or “our”) we believe that we have a responsibility to work with suppliers that source their products in a legal, ethical, and responsible manner consistent with the highest standards. Respect for people and relationships is the foundation of our business, and we strive to uphold and exemplify this principle every day. The information we have provided below, in compliance with the California Transparency in Supply Chains Act, explains how we are working to evaluate and address risks of slavery and human trafficking in our supply chain.

Verification

At CSO, we seek to work with suppliers engaged in responsible business conduct and believe open dialogue and collaboration can be an effective way to identify risk. We utilize our Supplier Code of Conduct (“the Code”) to communicate our expectations and guidelines concerning responsible sourcing, including human rights, health and safety, and business ethics. We have embedded several policies against forced labor and child labor within our Code. We ask our suppliers to sign the Code every two years. The policies in the Code include, but are not limited to:

  • Suppliers must comply with minimum working age Laws and not tolerate the use of child or forced labor, slavery, or human trafficking in any of their operations. Workers shall be allowed to maintain control over their identity documents and shall be provided with rest days as required by Laws. Suppliers must not produce any product or use any cotton from the Xinjiang Uyghur Autonomous Region in China, Uzbekistan, and other areas where forced labor is knowingly practiced. Any overtime working hours must be voluntary.
  • Suppliers must recognize and respect the individual’s right to choose whether to join a labor union, participate privately in trade associations, and collectively bargain.

CSO is engaging with the Fair Labor Association (FLA), an organization designed to help hold companies accountable to their labor rights initiatives by evaluating business practices against the highest international standards for global supply chains. At the date of this report, CSO is engaging in Milestone 2 with the FLA to become an accredited company. The accreditation applies only to our Owned Brands.

Additionally, CSO utilizes a software tool, Sayari, to monitor and track supply chain risks across available supplier data. This tool allows us to gain deeper insight into our supply chain beyond our immediate partners. Through the use of this tool and continuous communication, we maintain collaborative partnerships with each of our suppliers to advance the goal of identifying risk and building a more transparent supply chain.

Auditing

As part of our collaborative approach, when available, our suppliers share certification audit results with our team, and they are stored in an internal database. It is our supplier’s responsibility to maintain audits and corrective action plans, and to keep CSO updated of any necessary information.

Additionally, our work to gain accreditation for our Owned Brands with the Fair Labor Association includes SCI assessments selected from a random sampling of facilities recorded by CSO in FLA’s Fair Labor Data Hub. The assessments evaluate working conditions, address violations, and verify progress to meeting our milestone. The results and corrective action plans (CAP) are made public on the FLA website.

Further, CSO initiates full audits on our Owned Brand suppliers annually. These audits may consist of the following:

  • Factory Assessment of Product Safety and Quality Systems (FA – completed by Bureau Veritas)
  • Social Compliance Assessment (SA – completed by Elevate)
  • Customs-Trade Partnership Against Terrorism (C-TPAT)/Security Assessment (SE – Completed by Bureau Veritas)

Audits are announced to ensure the presence of appropriate management personnel, so they may provide best practice knowledge and training when a non-compliance is noted.

Certification

We expect our suppliers to comply with our Code, which contains several provisions outlining suppliers’ responsibilities with respect to preventing involuntary labor in their supply chains. The Code includes policies on Worker Health, Safety, and Security, Forced Labor, Child Labor, Discrimination, and Humane Treatment. The acknowledgment and signing of this Code serve as the supplier’s continuing affirmation of compliance.

Internal Accountability

We require all employees to comply with our Internal Code of Conduct and employee handbook. We have direct supervision of our employees and contractors, and in the event forced labor was used, employees and contractors would be immediately terminated. We also provide our employees with an ethics hotline to anonymously report non-compliance concerns.

Training

While currently we do not provide any formal training on human trafficking and slavery, our purchasing, products, and merchandising teams work hand in hand with each of our suppliers to maintain an educational and collaborative relationship.