The California Transparency in Supply Chains Act Disclosure Statement

Earthbound Trading Company, (henceforth referred to as "Earthbound" or the "Company"), is committed to conducting business in a lawful, ethical, and responsible manner. Earthbound extends this expectation to all Business Partners and does not tolerate slavery or human trafficking in any form, including forced, child, prison, indentured, bonded, or slave labor.

Earthbound makes this disclosure statement pursuant to The California Transparency in Supply Chains Act (2012), which requires disclosure of the Company's efforts to help eradicate slavery and human trafficking in supply chains. Below are several ways in which Earthbound is responding to demonstrate the Company's commitment to conducting business in a lawful, ethical, and socially responsible manner.


Earthbound is committed to enforcing fair labor practices within our supply chain. All Business Partners are required to acknowledge, complete, and sign Earthbound's Code of Conduct and Vendor Profile. The Vendor Profile provides information on the Business Partner's compliance measures. It includes all compliance-related licensure, all current or recent audits (including any accreditations and accreditation dates) if the Business Partner uses subcontractors, and if so, whether the Business Partner has compliance protocols in place to determine their compliance with applicable laws. The Code of Conduct ensures all Business Partners are responsible for maintaining working conditions aligned with Earthbound's ethical business practices.

Earthbound utilizes third-party auditors for Business Partners located in countries with higher risks of forced labor and/or poor workplace conditions. The auditors assess potential risk factors and report indications of human trafficking and slavery in the supply chain. The Company will calculate the risk(s) of a Business Partner through an evaluation of information received in; the U.S. Department of Labor's list of goods identified as vulnerable to forced labor, the Vendor Profile, information received from third-party auditors, the manufacturing process, the Business Partner's geographic location, and the history of human trafficking and slavery in the sector.

Earthbound reviews the conduct of active Business Partners on an annual basis to evaluate their risks and vulnerabilities to engage in slavery or human trafficking within their businesses and factories.

The Company's Team oversees the verification process using internally developed policies and assessments. The Company's Team cannot verify whether indirect vendors, utilized by Business Partners, comply with applicable laws governing slavery or human trafficking.

Business Partner (Supplier) Audits

When determined necessary, a third-party social compliance auditing company evaluates the Company's Business Partners. This ensures compliance with Earthbound's involuntary labor, anti-slavery, and human trafficking policy as stated in the Code of Conduct.

Audit inspections can be announced or unannounced, and consist of individual or group interviews with supervisors, management, and/or employees. Audits can include a tour of factories or businesses. If a Business Partner is identified as requiring improvement or remedial measures, additional audits or inspections will be necessary to ensure compliance.


Several provisions are included to ensure Business Partners uphold and enforce Earthbound's Code of Conduct. The Code of Conduct governs the contractual relationship with Business Partners, which states all Business Partners must abide by the highest ethical standards, are knowledgeable regarding the laws applicable to their businesses, and conduct their business in accordance with such laws. Earthbound requires Business Partners to ensure all persons employed are at least the local minimum legal working age or 15 years old, whichever is older. Earthbound also requires Business Partners to employ workers voluntarily and cannot be prisoners or engage in any other kind of forced labor. As part of the Code of Conduct, Business Partners must follow all applicable laws regarding minimum wage, overtime pay, working hours, and benefits. Business Partners must provide and maintain safe and healthy working conditions for employees in compliance with local laws. The Code of Conduct also explicitly directs Business Partners to appropriately investigate and address any complaints of corporal punishment or other threatening, abusive, or exploitative behavior.

The Code of Conduct permits Earthbound to engage in audits and other assessment activities to confirm compliance with the Code of Conduct. This includes unscheduled on-site inspections of facilities and records and private interviews with employees. As part of the Code of Conduct, Business Partners must maintain all necessary documentation on-site to prove compliance with the measures described above with respect to child labor, involuntary labor, health and safety, wages and benefits, and non-discrimination.

Business Partners are required to maintain sufficiently detailed records. These records must substantiate all materials supplied to Earthbound are produced in compliance with the applicable laws of the country or countries where they are produced. Business Partners are required to ensure any subcontractor used in the manufacturing or distribution of products for Earthbound complies with and adheres to the Company's Code of Conduct.

Working relationships are terminated between Earthbound and Business Partners who fail to sign the Code of Conduct and Vendor Profile, and who continue to be non-compliant. The Company's Team must approve an implemented corrective plan of action before continuing the relationship with non-compliant Business Partners.

Internal Accountability

Non-compliance with the Company's Code of Conduct regarding child labor, involuntary labor, and related practices will result in corrective action or termination of the Business Partner's relationship by Earthbound. The Company's Team works with employees and contractors to develop action plans to resolve instances of non-compliance. While Earthbound believes in sustainable remediation, the Company reserves the right to terminate a business relationship with an employee or contractor. The Company has developed internal accountability standards and procedures to ensure employees and contractors meet company standards regarding involuntary labor, anti-slavery, and trafficking. If the Company uncovers employee or contractor non-compliance, Earthbound will enact a written disciplinary notice of the issue with a corrective action timeline.


The Company's Team receives training on all company policies, including the Code of Conduct, company practices, and procedures. Additional training is completed annually to ensure that Earthbound's supply chain is free of forced labor, including the ability to identify warning signs of potential human rights violations.

Updated as of April 2023.