California Transparency in Supply Chains Act

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. This law was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

MDG USA, Inc. (“MDG”) is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers do the same.

MDG’s Vendor Code of Conduct explicitly entitles MDG to conduct unannounced [and independent] audits or investigations at any time in response to a possible violation by our direct suppliers of company standards for trafficking and slavery in supply chains. Because MDG strives to partner with direct suppliers who are governed by strict employment laws, at this time, we have not determined a need for additional verification or independent audit.

By signing or accepting our purchasing contract or purchase order, each of MDG’s direct suppliers certifies it conducts business pursuant to all applicable local and national laws and its failure to do so is considered a breach of the agreement.

Every employee and contractor is required to abide by MDG’s Code of Business Conduct. All new employees receive the Code of Business Conduct in their new hire information and sign an acknowledgement stating they have read it. Failure of employees to abide by MDG’s Code of Business Conduct is taken seriously, and can result in corrective action up to and including termination of employment.

MDG provides training for associates and management who work with our supply chains on the issues of slavery and human trafficking.