California Transparency Act

Bernhardt Furniture Company (Bernhardt) endeavors to conduct business in compliance with all laws and with widely accepted norms of fairness and human decency, and expects its suppliers to do the same. Bernhardt is committed to protecting the human rights and safety of the people who produce its products, raw materials and component parts used in production, while also recognizing and respecting the cultural and legal differences found throughout the world. Bernhardt pursues these goals through a variety of means; this disclosure is focused specifically on meeting the requirements of the California Transparency in Supply Chains Act.

Bernhardt prohibits illegal child labor, compulsory prison or slave labor, indentured labor, physical abuse of workers, corruption and unfair business practices in its operations and those of its suppliers. While Bernhardt does not typically require third party audits of suppliers’ facilities in regards to such illegal practices, Bernhardt expects its suppliers to maintain compliance programs around labor laws and to be able to demonstrate a satisfactory record of such compliance. Bernhardt personnel routinely visit suppliers and exercise Bernhardt’s right to inspect facilities during announced and unannounced visits. The frequency of such visits and inspections is generally related to the volume and importance of the goods or services supplied to Bernhardt’s overall operations.

While Bernhardt does not maintain an internal training program focused specifically on supplier labor law compliance and mitigating risks of labor law violations within the supply chains, managers responsible for purchasing decisions are informed of these risks and are expected to make the compliance expectations of Bernhardt known to the vendors and suppliers of goods and services. In some cases, written purchasing contracts are in place which expressly require the supplier, among other things, to comply with labor laws, which would include prohibitions against forced or child labor.

Bernhardt expects suppliers of goods and services to provide at a minimum the same scrutiny of their own supply chain to verify that those suppliers also comply with the labor laws of the country or countries in which they are doing business. At times, Bernhardt personnel visit and inspect the facilities of some of those upstream suppliers as well.

Bernhardt will address any identified violations or compliance issues with vendors and suppliers of goods and service on an individual basis. If prompt remediation does not occur or in cases where attempts at remediation are not judged credible, Bernhardt will cease to do business with the supplier.