Supply Chain Transparency Act

Sansa Costa Shoes (SCS) works with suppliers to protect human rights in our value chain by implementing a responsible sourcing program that requires compliance with the applicable laws and regulations of the United States, and regulations of the respective country of manufacture and exportation, and SCS's own due diligence efforts. In accordance with the California Supply Chain Transparency Act, we take the following actions to ensure that human trafficking and slavery do not exist in our supply chain.

At a minimum, disclose to what extent, if any, that the retail seller or manufacturer 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.

Verification:

To promote safe and legal working conditions in our supply chains that manufacture merchandise under our Sansa Costa Shoes brands, Sansa Costa Group has developed a Supplier Code of Conduct that aligns with International Labor Organization (ILO) and Customs and Trade Partnership Against Terrorism (CTPAT) standards and addresses a myriad of topics, including forced labor, child labor, working hours, discrimination, freedom of association, health and safety, global diversity, and environmental sustainability. Sansa Costa Group's private label suppliers are required to sign the Supplier Code of Conduct, which, among other things, requires them to disclose all owned and subcontracted manufacturing facilities used to produce Sansa Costa Shoes branded goods. Under this Code, vendors agree to comply with customary international standards and to inform all their workers across the globe of their rights. The Code also reminds vendors of their obligation to comply with all applicable national and local laws.

An independent third party engaged by Sansa Costa Shoes (SCS) uses this information to conduct a segmentation exercise that evaluates factories' risk by several factors, including country-specific public domain indices covering topics like labor, health and safety, business ethics, and the environment. The results of this exercise are used to assign each supplier a risk rating that informs which audit-related compliance activities they must complete.

Audits

To help verify compliance with NMG's Supplier Code of Conduct, Sansa Costa Shoes Group requires all imported Private Label suppliers who have signed the Supplier Code of Conduct to complete audit-related compliance activities based on risk assessment results.

Audits are conducted by an independent APSCA-certified auditor covering a range of topics and include worker interviews to better understand the working conditions at the facility. Audits are designed to evaluate, among other things, whether worker compensation is compliant with law.

Additionally, NMG regularly conducts CTPAT supply chain security audits (as part of the Customs and Trade Partnership Against Terrorism program) at our imported suppliers' facilities. Security auditors are trained to spot potential social compliance concerns (including indicators of forced labor) and to escalate them for further investigation by our independent third-party investigators. NMG makes clear to its suppliers that it will not tolerate, and will investigate, any human trafficking and slavery in the supply chain.

Certification

NMG requires all vendors, suppliers, third-party sellers, manufacturers, contractors, subcontractors, and their agents who conduct business directly with NMG to follow all applicable national and local laws in addition to customary international standards. Also, as noted above, all parties that manufacture merchandise under our Sansa Costa Shoes, brands are required to sign the Supplier Code of Conduct as part of their agreement to do business with NMG, this Code includes a reminder of their compliance obligation.

The standard terms of NMG purchase orders require all vendors to ensure that all merchandise has been produced in compliance with applicable law, including the Fair Labor Standards Act of 1938, as amended, the Uyghur Forced Labor Prevention Act, and analogous laws, regulations, rules, or restrictions of any other country with jurisdiction over the vendor or merchandise. Company procedures and standards, including the Supplier Code of Conduct and the NMG Code of Ethics and Business Conduct, that are made available to all suppliers on our operations portal, prohibit the direct or indirect use of convict labor, forced labor, labor obtained by human trafficking and/or slavery, indentured labor under penal sanction, child labor in the manufacture (in whole or in part) of any products supplied to Sansa Costa Shoes Group.

As noted above, Sansa Costa Shoes Group also partners with suppliers on continuous improvement efforts that support them in exceeding minimum requirements and create a positive impact for workers. Example certification programs we encourage suppliers to explore include Fair Trade USA (FTUSA), Fairtrade International, and Reimagining Industry to Support Equality (RISE). For more information, visit Neiman Marcus and Bergdorf Goodman's “Fashioned for Change” and “Conscious Curation” edits.

Internal Accountability

We maintain standards and procedures for all associates in the Sansa Costa Shoes Group Code of Ethics and Business Conduct, which directs employees to report any concerns about potential forced labor, among other things. Sansa Costa Shoes Group is committed to upholding fundamental human rights and believes that human beings around the world should be treated with dignity, fairness, and respect. Importation of goods produced by illegally employed underage workers, convicts, or involuntary labor is prohibited.

Training

Sansa Costa Shoes Group uses a digital learning platform to deliver social and environmental performance training to participating merchants and private label vendors, regarding human trafficking and human rights due diligence. Company personnel also attend conferences and trainings from groups like the Retail Industry Leaders Association, National Retail Federation, Global Fashion Agenda, and the American Apparel and Footwear Association to enhance internal awareness of emerging and established legislation and best practices related to labor and human rights issues.

Last Updated August 18, 2023