:: Compliance

 

The California Transparency in Supply Chains Act of 2010 Compliance

Windsor is committed to ensuring that slavery and human trafficking are not part of its direct suppliers’ supply chain. At Windsor, we hold ourselves and our suppliers accountable to high ethical standards where we do business. Our Suppliers Agreement, which includes our Conduct Standards and Suppliers’ obligation, is signed by every vendor as a condition of doing business with Windsor, requires vendors to certify that all of the products they supply to Windsor comply with the laws regarding slavery and human trafficking of the country or countries in which they are going business. Windsor’s Conduct Standards and training allow Windsor to maintain internal accountability standards and procedures for its employees or contractors who may fail to meet company standards regarding slavery and trafficking.

To monitor compliance with the expectations of Windsor’s Conduct Standards, Windsor or an independent third party, annually audits its suppliers through an assessment process. Supplier participation in this is mandatory. The three-stage assessment process includes a review of supplier responses to a detailed request for information. If during this review, Windsor indentifies any concerns or supplier responses require clarification, the supplier is moved into stage two, which includes a conference call or other meeting with that supplier to address the concern or clarification. If the issue cannot be resolved at this stage, the supplier moved to a third stage, which may include a supplier on-site audit. Depending on the nature of the concerns involved, these on-site audits may be unannounced. Failure to meet Windsor’s Conduct Standards would result in the termination of the supplier relationship.

Since implementing this Conduct Standards, Windsor has educated those employees and managers responsible for the supply chain management on this process and on how to mitigate risks within its product supply chains from slavery and human trafficking. Place contact us after you have reviewed this letter to discuss this matter further.