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California Transparency Supply Chain Act


On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. Under the law, manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s underlying purpose is to educate consumers, so they can make informed decisions and purchase goods from companies that responsibly manage their supply chains.


Bocks Inc., doing business as cleancult (and its subsidiaries, collectively “cleancult”) is dedicated to conducting business in a lawful and ethical manner. We are also committed to preventing any occurrence of slavery and human trafficking from our supply chain. Our Code of Conduct specifically prohibits labor practices that are inhumane, or which endanger the health and safety of our workforce and emphasizes our commitment not to do business with individuals or companies that engage in forced labor, unlawful child labor and/or human trafficking. Accordingly, it is our expectation that the manufacturers and suppliers with whom we do business will share our commitment to fair and safe labor practices and conduct themselves in a lawful and ethical manner. Consistent with this commitment, we have developed our Responsible Sourcing Standards, which prohibits the use of unlawful child labor and forced or involuntary labor of any kind. Additionally, we have also revised our Purchase Agreement to require our suppliers to represent and warrant that all labor and/or materials used in connection with the provision of any products provided to us were “employed and/or produced in compliance with applicable laws forbidding slavery and human trafficking.”


As good corporate stewards, cleancult will not work with any suppliers that engage in human trafficking and/or slavery. As part of our social responsibility, we ensure compliance with these obligations upon our suppliers, by evaluating a supplier’s compliance to our ethical standards. Through this process, we may conduct periodic, announced and unannounced assessments of our suppliers designed to verify their compliance with our ethical standards. These assessments are conducted by experienced cleancult personnel or a third party, as appropriate. Employees tasked with supplier compliance as well as other employees with direct responsibility for supply chain management are provided training on human trafficking and slavery, including ways to mitigate the risks of these practices within our supply chain. We educate employees our employees to identify non-compliance, and immediately report any potential unlawful or unethical conduct within the supply chain. Issues such as human trafficking, slavery, forced/prison labor and child labor are zero tolerance violations and cleancult will not only not conduct business with suppliers having such practices, but will also report them. Our audits allow us to verify that all labor at our suppliers' factories is voluntary.


As a condition of doing business with cleancult, all of our suppliers warrant that the products they supply to cleancult, whether private label brand or cleancult’s owned-brand, are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. cleancult’s standards expressly prohibit our suppliers from utilizing any forced or compulsory labor. They also mandate that workers receive fair wages and benefits in compliance with all applicable laws. cleancult will not do business with a vendor that fails to warrant such compliance. Moreover, cleancult will cease to do business with a vendor who fails to live up to that promise, and will also take actions toward reporting them,


cleancult utilizes a risk-based approach, which takes into consideration the general conditions of the country where the product is produced. For example, our verification of social responsibility standards consists of:

a) Internal and external audits;
b) Random onsite visits at factories;
c) Worker Interviews.


All Suppliers that sign our Manufacturing and Purchase Agreement must adhere to our comprehensive social responsibility requirements and are to follow all law and regulations in the jurisdictions in which our products are manufactured.

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