California Transparency in Supply Chains Act Disclosure

Josie Maran Cosmetics (JMC) is committed to respecting the human rights of its employees, suppliers, and communities in which it operates. JMC is committed to a work environment that values fair labor practices, quality assurance regulations, environmental laws, and ethical business practices within its global supply chain.

JMC expects all of the companies, factories, manufacturers, vendors, and/or agents that supply materials, produce goods, and/or provide services to JMC and any local affiliates (hereinafter “Suppliers”) to comply with all local regulations and national laws, including, but not limited to, those governing slavery and human trafficking, labor, employment, and occupational safety regulations and laws. Suppliers must comply with the policies and procedures contained in JMC’s Vendor Manual, Quality and Supplier Agreements and Supplier Code of Conduct which outlines the company’s expectations on quality, health, safety, sustainability, women’s empowerment, human rights, labor conditions, and includes a zero tolerance policy on human trafficking, slavery, child, forced, indentured, involuntary, prison, or uncompensated labor.

JMC is committed to working with its Suppliers to source materials, products, and services responsibly with uncompromising integrity.

VERIFICATION OF COMPLIANCE WITH LAWS

JMC is committed to fair labor practices within its supply chain by evaluating and addressing risks of human trafficking and slavery.

SUPPLIER AUDITS

JMC conducts annual audits of its Suppliers to determine whether they are complying with the company’s Vendor Manual, Quality and Supplier Agreements and Supplier Code of Conduct including requirements aimed at ensuring human trafficking is not tainting JMC products. JMC decides which suppliers to audit based on its assessment of the level or risk for slave labor or human trafficking practices in the country where the Supplier operates.

CERTIFICATION OF COMPLIANCE WITH SLAVERY AND HUMAN TRAFFICKING LAWS

JMC requires in its Supplier Agreements that each Supplier provide a certification, as a condition to doing business with JMC, that it is in compliance with all local regulations and laws, including those relating to anti-slavery and human trafficking, child and forced labor, human rights, harassment, and abuse, discrimination, and ethical practices and anti-corruption.

ACCOUNTABILITY

JMC has a zero tolerance policy on human trafficking, slavery, child, forced, indentured, involuntary, prison, or uncompensated labor. If a Supplier is found to violate JMC’s Quality or Supplier Agreement or Supplier Code of Conduct, JMC may, at its discretion, either terminate business with that Supplier or require the company to develop and implement a corrective action plan within a certain fixed time period.

TRAINING

JMC’s Quality, Regulatory & Sustainability Department is responsible for ensuring all JMC suppliers are in compliance with supply chain regulations. JMC maintains internal accountability standards and procedures and provides annual training to ensure that employees are knowledgeable and aware of the issues and concerns surrounding the supply chain including monitoring and mitigating the risk of human trafficking and slavery.

SUPPLIER CODE OF CONDUCT

JMC’s Supplier Code of Conduct applies to any companies, factories, manufacturers, vendors and/or agents that supply materials, produce goods, and/or provide services to JMC (referred to as "Suppliers") to comply with all local regulations and national laws, including, but not limited to, those governing slavery and human trafficking, labor, employment, and occupational safety regulations and laws.

JMC strives to develop and maintain long-lasting, trusting, and mutually beneficial relationships with Suppliers who share its core philosophy and who are committed to operating responsibly and ethically. This commitment requires all of our Suppliers to fully comply with this Supplier Code of Conduct, as detailed below:

Legal Compliance: JMC is committed to conducting its business in accordance with the highest ethical standards and in compliance with all applicable laws and regulations in the countries where it does business. JMC’s goal is to meet or exceed requirements of applicable quality, environmental, health and safety laws and regulations and expects its Suppliers to do the same.

Child and Forced Labor: JMC Suppliers must not employ child, forced, or compulsory labor of any kind including prison, bonded, indentured or otherwise. Mandatory overtime is forbidden and workers must be allowed to leave their employment after giving reasonable notice.

Human Rights, Harassment and Abuse: JMC Suppliers must treat their employees with respect and dignity. They must not engage in any kind of corporal punishment, physical, verbal, psychological or sexual abuse or misconduct.

Human Trafficking and Slavery: JMC requires all of its Suppliers to assess the risks and vulnerabilities to slavery or human trafficking in the production of the production of goods and verify their compliance with all local labor regulations and laws,

Hours and Wages: JMC Suppliers must comply with the local legal limit on hours worked. Workers must receive at least 1 day off each week and must not be required to take work home. JMC Suppliers must pay their employees the legal minimum wage or the prevailing industry wage (whichever is higher) as well as pay any legally prescribed benefits. Workers must not be subject to financial penalties or deductions from wages as a form of discipline.

Discrimination: JMC Suppliers must treat all of their employees equally and fairly and must not subject their workers to any unfair or unjustified discrimination with regard to hiring, remuneration, promotion or termination. JMC Suppliers must not discriminate on personal characteristics such as race, creed, color, religion, gender, age, national origin, alienage or citizenship status, sexual orientation, gender identity or expression, marital, partnership or familial status, disability, genetic information, veteran/military status, domestic violence victim status or any other legally protected group.

Freedom of Association: JMC Suppliers must recognize the right of employees to freely associate and must comply with all local laws governing the right of employees to select or not to select workplace representatives.

Health and Safety: JMC Suppliers must ensure that their workers perform their work in clean, healthy, and safe environments. Supplier premises must be of a standard to prevent accidents and illnesses and to ensure an adequate level of sanitation.

Environment and Sustainability: In addition to compliance with local and international environmental laws and regulations. JMC Suppliers must strive to continually improve their sustainability performance record.

Subcontracting: Subcontractors must agree to abide by JMC’s Supplier Code of Conduct. Manufacturing facilities may not be changed without advance written notice to and approval by JMC.

Communication: JMC Suppliers must make all reasonable efforts to communicate the JMC Supplier Code of Conduct to workers and must ensure that workers have the opportunity to ask questions and make complaints under the Code.

Ethical Practices and Anti-Corruption Policy: All JMC Suppliers and their officers, directors and employees must adhere to the highest standards of business ethical conduct and must not engage in any corruption activities including extortion and kickbacks.

Improper Payments, Gifts and Entertainment: JMC employees may not give or receive gifts or entertainment unless they are not provided as a quid pro quo, are modest in value, infrequent, unsolicited, given on a customary gift giving occasion, reasonable and customary in our business and permissible under the rules of the Suppliers’ organization.

Verification of Compliance: JMC will work with its Suppliers to ensure that they fully understand the intent and requirements of the Supplier Code of Conduct. If JMC determines that a Supplier is not in compliance nor makes any effort to comply, then at JMC’s discretion, the remedies may include, among other things, termination of business with JMC or the development and implementation of a corrective action plan that would need to be implemented within a certain fixed time period followed by an audit if appropriate.

Inspections, Audits and Access to Information: JMC approves new suppliers and new manufacturing facilities that pass both its Supplier Code of Conduct audits and a quality assurance audit. JMC may conduct Supplier compliance audits at any time without notice. JMC Suppliers must provide in English any requested written quality GMP documentation to verify compliance with applicable laws and regulations and JMC’s Supplier Code of Conduct