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One of our core values is to “Do the Right Thing - Always.” . We recognize the importance of responsibly sourced products and are committed to working with supply chain business partners that are dedicated to safe, humane, and ethical working conditions that comply with international labor standards. We have established guidelines to assist in our efforts to select partners who share our ethical commitments. BACK&BRANA has zero tolerance for forced labor, human trafficking, and slavery or involuntary work of any kind anywhere in our supply chain.

Pursuant to the requirements of the Modern Slavery Act of 2015 and the California Transparency in Supply Chain Act of 2010, BACK&BRANA makes the following disclosures of our reasonable efforts to ensure that slavery and human trafficking do not occur in our supply chain:

DUE DILIGENCE

Risk Assessment

BUCK&BRANA utilizes internal and external audit information as well as international labor resources to assess risk of potential supplier partnerships. All new factories are assessed prior to production and must be approved by the Company’s Social Compliance Team.

 

Auditing and Verification

All factory partners receive a copy of our Production Code of Conduct and new factory orientation which further communicates our Social Compliance Program requirements and auditing processes. The Company has a Standard Operating Procedure and Assessment Tool that guides our auditing team and external partners. Wolverine utilizes a combination of internal and external auditors. The Company’s staff of internal auditors,  are aided by industry-leading third-party audit directed by GPA law firms who assist with BUCK&BRANA´s audit program.

As a general rule, our factory partners are subject to annual audits. BUCK&BRANA reserves the right to conduct unannounced inspections of its factories where appropriate.

ACCOUNTABILITY

BUCK&BRANA maintains internal accountability procedures to ensure Company standards on slavery and human trafficking. Furthermore, decisions regarding where and what direct suppliers to engage in our supply chain do not occur at the local level. Instead, those decisions are made  with appropriate input from our Product Integrity Group, brands, auditors, and others as appropriate to avoid actual or apparent conflicts of interests and to ensure appropriate review and audit of direct supplier operations. BUCK&BRANA requires compliance with its Production Code of Conduct, and we maintain a zero-tolerance policy with respect to human rights violations including slavery and human trafficking, forced labor, child labor, life-threatening health and safety conditions, harassment, and discrimination. BUCK&BRANA will terminate any factory relationship where any of these zero tolerance violations are confirmed.

TRAINING

BUCK&BRANA trains its employees who are directly responsible for sourcing finished goods on mitigating the risk of slavery and human trafficking in our supply chain. Strict audit guidelines are provided to the Company’s internal auditors when visiting production partner facilities. Audit results are reviewed by the Company’s Product Integrity group and any findings of non-compliance are reviewed by the Company’s Legal Department.

BUCK&BRANA also provides training to our factory partners to ensure understanding of our requirements and provide an opportunity to share best practices. An annual Social Compliance Summit is held with all factory partners and targeted training in local language assists in continuous improvement of specific areas of the Production Code of Conduct

 

 

REPORTING VIOLATIONS

BACK&BRANA maintains a report line so that employees, as well as employees of our contracted factories and suppliers, may always ask any question or raise any concern confidentially, and anonymously if desired. The Report line number operates 24 hours a day and is available anywhere in the world in multiple languages at (832) 6606113 or hello@buckandbrana.com.  The Company strictly prohibits any form of retaliatory action being taken against employees who report known or suspected violations.