Supply Chain Act

Orgain was founded with the purpose of inspiring healthy, vibrant lives. As such, the company has zero tolerance for slavery and human trafficking within our supply chain and believes that no individual should be deprived of basic needs and fundamental rights. Orgain is committed to fair employment practices and to following applicable employment law wherever it has operations. More information regarding Orgain’s efforts to mitigate the risks of slavery and human trafficking throughout our supply chain is available below.

Verification

Orgain does not currently engage in verification of our product supply chains to evaluate and address risks of human trafficking and slavery. However, Orgain has established and promulgated a Supplier Code of Conduct that our direct suppliers are required to sign. The Supplier Code of Conduct requires such suppliers to certify that materials incorporated into their products comply with laws regarding forced labor and child labor in the country or countries in which they do business. One tool Orgain will employ is to monitor the United States Department of labor lists of Goods Produced by Child Labor or Forced Labor.

Audit

Orgain reserves the right to audit our suppliers and to engage a reputable third-party monitoring firm to audit and work with the supplier to find corrective solutions if violations are suspected.

Certification

As described above, Orgain requires its direct suppliers to certify that materials incorporated into their products comply with laws regarding forced labor and child labor in the country or countries which they do business. If Orgain becomes aware of any actions, circumstances or conditions not in compliance with the Supplier Code of Conduct, Orgain may select a third-party monitoring firm to work with the supplier to find lawful resolution. Orgain reserves the right to terminate an agreement with a supplier or any other commercial relationship due to violations of the Supplier Code of Conduct or other conduct which does not match our company ethos, which includes a prohibition on the use of child, prison or forced labor.

Internal Accountability

Orgain maintains and enforces internal accountability standards for team members, including explicit prohibitions on the use of child, prison or forced labor in Orgain’s operations. Orgain provides multiple channels to report concerns about a potential violation of law, company policy, or Orgain's Supplier Code of Conduct. We respond promptly and conduct investigations when appropriate. If any employee or supplier is found in violation of this policy, Orgain intends to take prompt, remedial measures to address the violation up to and including suspension and or termination.

Training

Orgain is committed to responsible and ethical sourcing for its products and intends to provide training to our employees and supply chain professionals on human trafficking and how to eliminate it from our supply chain.  The content of training may vary over time to address changing needs; but may typically include topics such as:

• what human trafficking is and why it occurs

•  types of human trafficking that affect the supply chain

•  how to assess the risk and identify instances of human trafficking

•  how to respond when there are indications of human trafficking