ME+EM California Transparency in Supply Chain Act (SB 657) Statement

Operating as a fair and responsible brand are core values at ME+EM. We are committed to the respectful treatment of people across our supply chains. We require all our suppliers to adopt our strict code of conduct and responsible sourcing policies.

In compliance with the California Transparency in Supply Chains Act of 2010 (SB 657), we are providing the following disclosure about our responsible product sourcing policies and our responsible sourcing actions. We want to provide California customers with the information they need to make responsible and informed purchasing decisions when purchasing from ME+EM. Specifically, we want California customers to have the details about how we are working to identify and address risks of slavery and human trafficking in our supply chain.

Disclosure of ME+EM pursuant to SB 657:

The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, that the retail seller or manufacturer does each of the following:

(1) Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

Led by our dedicated in-house CSR team, we collaborate with leading industry expert organizations to inform our environmental, social and governance (ESG) framework, as well as our sustainability pillars: Product, People, Planet + Community. To uphold this commitment, we proudly stand as members of both the Ethical Trading Initiative (ETI) and SEDEX (global leaders in social compliance) The ETI is a powerful force driving long-term change and worker empowerment across the globe. Since becoming a member in 2022, we’ve adopted their internationally recognized base code of labour standards as the foundation of our own code of conduct, particularly focusing on protecting and promoting workers’ rights and the prevention of modern slavery. For example, our code of conduct requires our suppliers to comply with our Forced Labour and Human Trafficking Policy, in which we have identified Uzbekistan, Turkmenistan, Myanmar, and XUAR (Xinjiang Uyghur Autonomous Region) in China, as locations in which our suppliers cannot make goods for us. Supplier audits are conducted by independently approved third parties within agreed timescales and frequency.

With a truly global footprint, we have invested in a PLM digital platform (Product Lifecycle Management) to map and enhance transparency across our materials and supply chains. Our goal is to empower both our partners and our customers with the clarity and traceability they deserve.

(2) Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

Our SEDEX membership further reinforces our commitment to responsible supply chain management, enabling us to engage in global auditing programs that provide both insight and accountability. We use SEDEX’s globally recognized auditing methodology, Sedex Members Ethical Trade Audit (SMETA), as the benchmark for monitoring and assessing our suppliers’ approach and performance to preventing human rights violations in their supply chains. All ME+EM suppliers are required to undergo regular social audits by independent auditing bodies, and we require all our suppliers to be members of SEDEX so that we have full transparency of their business operations and how their workers are treated. Our SMETA 2-Pillar audits are governed by the standards contained in the Ethical Trading Initiative base code, specifically reporting on labour standards and health & safety. In some instances, suppliers will undergo SMETA 4-Pillar audits which include more extensive environmental management requirements as well as business practices. The auditing reports for our suppliers are held on the Sedex database which is also used as an interactive tool for suppliers to upload appropriate information that gives us greater visibility of their ethical practices. If we were to learn of an alleged non-compliance with our policies or other violation of human rights, it would be escalated and investigated immediately, with priority given to finding remedy for the workers. The supplier would also be given a summary of the actions required to resolve the issue and a time frame in which to do so.

We additionally use SEDEX’s Risk Radar platform and resources to conduct risk assessments for all countries where we source and produce our collections, we also use the platform to assess the potential risk of sourcing in new countries. The country risk scores allow us to identify and monitor broader socio-economic factors that could increase the risk of human rights related violations. Our CSR and product teams regularly visit our factories and promote the importance of worker representation within the manufactures and conduct supplier surveys to gauge feedback.

In addition, we have developed an internal reporting system to record the summary of each supplier’s audit and highlight any noncompliance. For any noncompliance that is found during an inspection the auditor provides a rating depending on the perceived criticality, we then consider this alongside our own high expectations and allocate a score that highlights the remedial attention required. This information is presented as a dashboard which is divided by supplier origin. This is important as we can easily see trends that can be endemic to certain countries and regions. The dashboard alongside a summary of priorities is cascaded monthly to a member of the senior leadership team. Although SMETA provides recommended time scales for resolving noncompliance’s, we will request that a supplier takes faster action if we believe that workers are at potential risk.

(3) Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

We tirelessly collaborate with our suppliers to ensure our values are upheld throughout our supply chain. This is communicated through a comprehensive code of conduct, preferred material guidelines and sourcing policies. We are committed to increasing our use of certified traceable materials, as these standards promote a high standard of social compliance and transparency, tracing the finished materials back to the original raw material.

We are certified as a brand to the Responsible Animal Fiber standard, encompassing responsible wool, mohair and alpaca and the Good Cashmere Standard. In addition, we purchase certified GOT’s organic cotton, which upholds strict social compliance. Our cotton sourcing policy also prohibits sourcing from Uzbekistan, Turkmenistan and Xinjiang.

(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

We have established a clear escalation and remediation process in the event we find or are presented with credible evidence of noncompliance with our policies or other human rights violations in our supply chains. We are committed to protecting the rights of the workers in such scenarios and consider the ethical and commercial impacts of our decisions.

Although we may consider termination of a business relationship, if a critical issue of noncompliance is identified or when a supplier is unwilling to comply with our requirements, despite our efforts to help them become compliant, we prefer to engage with the affected supplier and offer support to remedy the situation to provide stability for the workers.

For employees directly employed by ME+EM we also provide a whistle blowing procedure in the employee handbook which explains how an employee can communicate concerns through internal escalation or contact details for an independent organization where advice and support can be obtained. In addition to this we provide contact details for a dedicated modern slavery helpline. As part of our forward objectives, we are assessing grievance and whistleblowing mechanism options for our stock suppliers.

(5)Provides company employees and management who have direct responsibility for the supply chain with management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.

Our internal buying teams undergo responsible purchasing practice training by the ETI, ensuring our sourcing methods remain ethical, fair and transparent. We are supported internally by our dedicated Ethical Trading Manager who regularly engages with ETI to cascade relevant training and awareness.