Supply Chain Policy

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURE

  1. Verification – O’Neill Vintners & Distillers, (“O’Neill”) expects its suppliers will remain in compliance with all applicable laws including labor laws. Should O’Neill become aware of non-compliance, appropriate action will be taken. O’Neill does not plan on using a third party for verifications.

  2. Audits – O’Neill expects its suppliers will comply with its standards for human trafficking and slavery. Should O’Neill become aware of non-compliance, appropriate action will be taken. O’Neill does not plan on using independent, unannounced audits.

  3. Certifications – O’Neill expects to expand its process to require direct suppliers to certify that activities related to the California Transparency in Supply Chains Act of 2010 are in compliance with all applicable labor laws.

  4. Accountability – O’Neill expects to evaluate whether supplemental accountability standards and procedures for employees and/or contractors are appropriate.

  5. Training – O’Neill expects to evaluate whether supplemental training of employees and managers, who are directly responsible for supply chain management, on human trafficking and slavery, specifically with respect to further mitigating risks within the supply chains of products, is appropriate.