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The California Transparency in Supply Chains Act of 2010


This document describes The Gymboree Corporation’s (“Gymboree”) response to The California Transparency in Supply Chains Act of 2010. For additional information about our ongoing efforts to support human rights and fair labor practices at the factories used by the vendors that produce Gymboree branded product, please go to our Social Responsibility page.


Verification of the supply chain to evaluate and address risks of human trafficking and slavery

We are committed to making a difference inside and outside of our company, and this begins with giving kids a chance to be kids and producing quality products that make us proud.


Gymboree regularly monitors and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. We work with third party auditing firms that provide the support and resources needed to help us identify, assess and manage labor issues throughout our supply chain. All factories that are set up to receive orders from Gymboree are audited and evaluated against our Terms of Engagement as well as other requirements included in our Monitoring Standards. Included in the auditing process is an assessment of working conditions and any potential risks associated with the use of labor brokers or third party recruiters and warning signs related to potential slavery and human trafficking issues. These initial audits are unannounced as are all subsequent audits, including, without limitation, audits to confirm corrective measures have been put in place and yearly audits to confirm continued compliance with our Terms of Engagement. Our vendors certify that they and their supply chains abide by local laws and comply with our Terms of Engagement and Monitoring Standards. Violation of our Terms of Engagement can lead to deactivation as a viable site for Gymboree production, cancellation or re-assignment of work orders and/or loss of the ability to receive any future orders.


If any risks are identified, our social compliance team works directly with our head of Sourcing and Production to determine if we should proceed with sourcing from the new country.


Audit of the supply chain to verify compliance with standards for human trafficking and slavery


Gymboree uses independent third party auditors to conduct unannounced social audits on all of our factories. Gymboree will not work with any vendor that will not allow Gymboree’s third party auditors to conduct unannounced audits in their factories. All of our vendors are required to comply with our Terms of Engagement and are responsible for ensuring that the factories meet or exceed each of our monitoring standards. During the audit, our auditors measure the factories against our Terms of Engagement.


Verification that suppliers of materials incorporated into Gymboree’s products comply with laws regarding human trafficking and slavery


In our Terms of Engagement, we require that our Vendors only source raw materials that are incorporated into our products from suppliers who comply with all applicable laws, including, without limitation, the laws regarding slavery and human trafficking.


Accountability Standard


In the event that we identify a potential violation of labor or human rights issues, Gymboree will promptly address the issue with the vendor and outline specific steps for correcting the issue according to our remediation process.


Internal Accountability


Gymboree is committed to conducting business lawfully and ethically in every jurisdiction and country in which we operate. We set high standards for the Company's employees, officers and directors. It is important that each of our board members, officers, employees, agents, consultants, vendors, and contractors be guided by our Business and Ethics Code of Conduct. Failure of employees to follow Gymboree’s Business and Ethics Code of Conduct can result in corrective action up to and including termination of employment. Gymobree’s Business and Ethics Code summarizes the standards, values and principles that act as our guide to making the right business decisions for Gymboree.


Training on human trafficking and slavery


Gymboree is committed to conducting business lawfully and ethically in every jurisdiction and country in which we operate. We set high standards for the Company's employees, officers and directors. It is important that each of our board members, officers, employees, agents, consultants, vendors, and contractors be guided by our Business and Ethics Code of Conduct. Failure of employees to follow Gymboree’s Business and Ethics Code of Conduct can result in corrective action up to and including termination of employment. Gymobree’s Business and Ethics Code summarizes the standards, values and principles that act as our guide to making the right business decisions for Gymboree.


Gymboree is committed to upholding fair labor practices and human rights in every aspect of our supply chain. We will continue to enhance our social responsibility program as we learn from our experience on how to best address labor and human rights throughout our supply chain and we will continue to align our program with industry best practices, including in the areas of slavery and human trafficking.