INTRODUCTION

 

Berluti SA and its affiliated companies (collectively, the “Berluti Group”) supports the goals of the California Transparency in Supply Chains Act of 2010 (the “Act”) and strives to be a model example of human rights and fair labor practices throughout its business activities. The Berluti Group chooses the best suppliers in its field who provide premium quality in both their products and services but also by way of their ethical, social and environmental approaches and beliefs. To this end, the Berluti Group chooses its suppliers based upon their ethics, honesty, and integrity in their business dealings, as well as the social and environmental principles by which they operate.

The implementation of the Act presents the opportunity for the Berluti Group to reaffirm its commitment to enforcing measures that fight against slavery and human trafficking.

 

As a responsible corporate actor, the Berluti Group’s actions in this area include the following:

 

VERIFICATION REQUIREMENTS FOR SUPPLIERS

 

The Berluti Group has implemented the Berluti Group Code of Conduct (the “Code”) and requires all suppliers (including their subcontractors involved with the manufacturing process for Berluti’s products) to agree to and adhere to the terms of the Code. The Code sets forth and establishes non-negotiable minimum standards for the Berluti Group’s suppliers in the areas of health and safety, labor standards, business integrity, and the environment. In addition, the Berluti Group may conduct supplier audits, described below, in order to verify that its suppliers are complying with the Code. SUPPLIER AUDITS

The Berluti Group audits suppliers that, based upon an analysis of the volume of the supplier’s business and the risk of abuses in the country in which the supplier is located, pose a high risk of working condition violations to ensure that its suppliers are compliant with the Code.

 

CERTIFICATION OF SUPPLIER COMPLIANCE

 

The Berluti Group requires its suppliers to sign and to adhere to the Code.

 

MAINTAINING ACCOUNTABILITY

 

In the event the Berluti Group becomes aware of any actions or conditions not in compliance with the Code, the Berluti Group reserves the right to demand corrective measures as well as the right to terminate an agreement with any supplier who does not comply with the Code.

 

TRAINING TO COMPANY EMPLOYEES

 

The Berluti Group and its employees endeavor to respect the laws and regulations in all countries in which they operate, and conducts its business according to principles outlined in the International Labour Organization and the United Nations Universal Declaration of Human Rights.

The Berluti Group will continue to evolve and adapt its policies and procedures to a changing world in order to reflect the Berluti Group’s unwavering commitment to ethical business principles.