Transparency in Supply Chains Act

In compliance with the regulations of the California Transparency in Supply Chains Act (SB 657), the following document discloses our policies and actions relating to slavery and human trafficking in business and the supply chain.

Our Company

Haute Rack, Inc. is doing business in San Francisco, California, United States. We provide goods online which are sourced from various manufacturers worldwide. We are a privately held corporation. A significant portion of our business involves sourcing finished apparel from manufacturers of the world’s largest brands. In addition to this, we also manufacturer brands that we own and/or license, in which we sell to retailers across the globe. The main focus of our compliance efforts revolves around meeting the high standards and expectations of the brands for which we produce.

At Haute Rack, our core values of honesty, integrity and respect are embedded in everything we do and are publically declared in Haute Rack’s Code of Ethics and Code of Conduct. We believe in partnering with others who share our values and who understand the importance of always conducting business ethically.

We are committed to taking steps to end forced labor, whether in the form of human trafficking, indentured labor, prison labor or otherwise. We do not knowingly work with factories that use forced labor, are involved in human trafficking, or slavery. This statement outlines many of our efforts to eradicate forced labor from our direct supply chains.

Risk Management & Verification

We practice risk management in our supply chain through a variety of methods, mainly by auditing our tier 1 suppliers. Auditing enables us to evaluate compliance with our company code of conduct as well as our customers’ standards. 100% of our tier 1 suppliers, which produce either our own brand labels or licensed labels, are audited through either our own internal auditors, our customers or a qualified third party auditing firm. The majority of our audits are announced or semi-announced. With respect to our owned brands, we audit a minimum of 40% of the facilities that run our production and are committed to increasing this annually. These suppliers are audited through a combination of internal and 3rd party firms and these audits are generally announced.

In addition to auditing, we use a variety of industry tools, such as the US State Department’s Trafficking in Persons Report, to help focus our efforts in areas where we believe slavery and human trafficking have the greatest risks. These areas can include countries which host and/or employ migrant workers, areas in which entities or governments are not playing a crucial role in preventing slavery and human trafficking, as well as suppliers further removed from our immediate supply chain (Tier 2 and Tier 3). Some of these countries include China, Thailand, Cambodia, India, and Vietnam.

At Haute Rack, we have set forth policies to address human trafficking and slavery in our supply chain. We have developed our internal code of conduct, aligning with our customers’ and Fair Labor Association codes of conduct. These codes are issued to all tier 1 suppliers and are typically the basis against which the audits are conducted. Through acceptance of our business and our code, contracted factories are agreeing to comply with all of the principles outlined in our code. These principles address topics such as child labor, forced labor, legal wages, discrimination, and harassment, and prohibit human trafficking and slavery in the supply chain. Each manufacturing partner is required to maintain records that are sufficiently detailed to substantiate that all materials it supplies to us are produced in compliance with the anti-slavery and human trafficking laws of the country or countries where they are produced. Such records may include: (1) proof of age for every worker; (2) every employee’s payroll records and timesheets; (3) written documentation of terms and conditions of employment; and (4) records of employee grievances and suggestions, along with employer responses.