California Transparency Act

Forced labor is a serious violation of human rights. It can involve trafficking, debt bondage, compulsory service, coercive work arrangements, or the exploitation of children. Although these abuses take different forms, they share a common feature: people are made to work through force, deception, threats, or other forms of pressure for someone else’s benefit. Laws and international efforts have increased awareness, yet exploitation remains difficult to identify and prevent, particularly when it is concealed within informal employment or complex supply chains.
Understanding the scale of forced labor is challenging. Such practices are often hidden, and workers may be too frightened or isolated to speak openly. Legal definitions and data collection methods also vary between countries, making it difficult to compare reports or establish a complete picture. Control does not always involve physical restraint. Employers or intermediaries may use threats, withheld wages, fabricated debts, confiscated identity documents, or intimidation related to a worker’s immigration status. These tactics can leave people feeling that they have no safe or realistic way to leave.
Workers facing poverty, insecure housing, limited legal protections, or language barriers may be especially vulnerable to exploitation. In some industries, people may be recruited with false promises about pay or working conditions and later discover that their earnings are being withheld or reduced by unexplained fees. Others may be threatened with losing accommodation, facing legal trouble, or having family members harmed if they try to seek help. These forms of pressure can persist for a long time, especially when workers have little contact with people outside the workplace.
Businesses have a responsibility to understand and address risks throughout their operations and supply networks. In several jurisdictions, laws require certain companies to report on the steps they take to identify and respond to trafficking and forced labor. Public disclosures may describe how a company evaluates risk, works with suppliers, conducts due diligence, and responds when concerns arise. Transparency can help strengthen accountability, but a published statement alone does not prevent abuse. Prevention requires ongoing attention, credible oversight, and a willingness to take corrective action when problems are found.
Our company operates through entities in several regions of North America and participates in an international group led by a parent organization based in the United Kingdom. The business began in the mid-1990s, when a collective of independent makers set out to create personal care products inspired by botanical ingredients and thoughtful production. From its early days, the company emphasized freshness, quality, and relatively simple formulations using plant extracts, oils, and butters. Many products remain plant-focused, and a substantial portion are vegan.
As the business expanded, its operations developed across multiple countries. Manufacturing takes place in facilities located in Europe, North America, and Australia, while distribution centers supply products to retail locations in different markets. Production levels may change during busy seasons, sometimes requiring temporary workers to support increased demand. These arrangements make effective planning and appropriate workplace safeguards especially important, so that production needs do not come at the expense of fair and safe conditions.
Materials are sourced through networks of suppliers and manufacturing partners. Because supply chains can involve many businesses and regions, understanding working conditions requires cooperation and continued review. We expect ethical standards to guide relationships across this network and recognize that effective oversight depends on clear communication, suitable checks, and the ability to respond to concerns. A supplier’s assurances alone may not reveal every risk, particularly where labor is subcontracted or recruitment is managed by third parties.
We aim to strengthen responsible sourcing by examining how materials are obtained and how products are made. This work includes identifying areas where workers could face heightened risks, seeking information from business partners, and improving practices as new concerns or expectations emerge. When an issue is identified, an appropriate response should focus on protecting affected people, addressing the underlying conditions, and preventing similar problems from recurring.
The effort to prevent forced labor is ongoing. No company can assume that its supply chain is free from risk simply because policies are in place. Progress depends on consistent attention, meaningful accountability, and respect for the rights and dignity of every worker connected to the production of our goods.