SECTION I
DEFINITIONS AND CERTIFICATIONS OF COMPLIANCE
5/24/2018 1 TABLE OF CONTENTS
Definitions and Standards……………………………………………………3-4
Certification of Compliance……………………………………………………..5
Transshipment Certification of Compliance………………………………….6 DEFINITION AND STANDARDS
G-III Apparel Group, Ltd. ("G-III") is committed to legal compliance and ethical business practices in all of our operations worldwide. We choose business partners who we believe share that commitment. We have placed or are considering placing, one or more orders with your company for the manufacture of apparel or for the performance of services with regard to the manufacture of apparel. We would like to call your attention to G-III's policy with regard to legal compliance and ethical business practices.
We have defined business partners as contractors and suppliers (and their respective sub- contractors and sub-suppliers) who provide labor and/or material utilized in the manufacture of our products, regardless of G-III’s role as purchaser or sourcing agent.
In our purchase arrangements, business partners must observe all applicable laws of their country, including laws relating to employment, discrimination, the environment, and safety in the apparel and related fields. Moreover, business partners must comply with applicable U. S. Customs laws relating to the import of products, including country of origin labeling, product labeling and fabric and product testing. If local or industry practices exceed US legal requirements, this higher standard should be met.
Our standards are summarized as follows:
1* Our business partners must share our commitment to compliance with all laws regarding the importation of merchandise into the United States or other importing nation. Our business partners must respect the U. S. Customs laws for importation and the laws concerning the transshipment of merchandise. Transshipment is illegal and G-III will not tolerate this type of transaction for purposes of evading quota or country of origin rules. Vendor must allow G-III the opportunity to review pertinent internal records to verify vendor’s compliance. 2* Our business partners must share our commitment to providing a safe and healthy workplace and to treating employees fairly and in compliance with local laws. Worker housing, where provided, must meet the same standards for health and safety as the workplace. Employees must be compensated fairly for all hours worked and at rates that meet local industry standards. Employees must not be discriminated against because of personal characteristics or beliefs.
5/24/2018 3 3* Our business partners must not utilize child labor as defined by the United Nations standards or by national standards, whichever are higher. They must not utilize forced labor, including prison or other compulsory labor. 4* Protection and preservation of the environment. Assuring vendor compliance includes the following key components and formal documentation of these activities: a) Annual completion of the G-III Business Partner (Vendor Profile) b) Regular in-line and final inspection of all orders by G-III designees with a reporting section specifically covering observation of the compliance of these standards. c) All vendor purchase orders issued with clearly stated compliance requirements. d) Unscheduled factory visits for the express purpose of identifying legal, safety and policy compliance. e) Regular recertification of all facilities by authorized Quality Control staff. f) Annual recertification of these Operating Guidelines to all active business partners.
If it is found that a business partner has committed legal violations, or deals with a sub- contractor or sub-supplier that has committed legal violations, or is not in compliance with the standards set forth herein, we will take appropriate action, which may include canceling the affected purchase contract(s), terminating our relationship with that business partner, commencing legal actions against the supplier or contractor, or other actions as warranted. Additionally, G-III may assess penalties equivalent to all damages incurred by G-III to rectify non-compliance of the local and US laws already described.
Your endorsement of this letter will reconfirm our authorization to send a G-III representative or agent to your premises from time to time to perform such work as is necessary to ensure that you are in compliance with our standards. You agree to cooperate fully and to provide our representative or agent with any and all information requested which is necessary to prove your compliance with the applicable laws or other matters reviewed.
Please sign and return to us a copy of this Certification of Compliance, which evidences your agreement to comply with G-III's policy, and with the employment standards and legal requirements of your country, with respect to the manufacture of all goods and services, which you supply to us. If you have any questions concerning compliance with the applicable laws of your country, we suggest that you consult your local authorities.
Please confirm your agreement with all of the foregoing by signing this letter and returning it to us promptly.
CERTIFICATION OF COMPLIANCE
By my signature below, as chief executive officer, and on behalf of my company, I acknowledge receipt of the above G-III Apparel Group’s Business Partner Operating Guidelines, and do hereby certify and agree that my company will comply with all applicable labor laws, US Import regulations, and order terms and conditions set forth for any and all goods supplied to or through G-III regardless of country of origin. My company also agrees to assessed payment penalties for damages to G-III in the event of failure to comply with any of the above requirements.
______(Print) Name & Title - Chief Executive Officer
______Company Name & Address
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______Signature
______Date
5/24/2018 5 G-III APPAREL GROUP LTD. 512 Seventh Avenue New York, NY 10018 212-403-0500 212-403-0551 Fax
Sam Deutcher Head Of Operations
Dear Valued Vendor:
There has been a great deal of comment and publicity concerning transshipment in the Far East. Transshipments an illegal practice of falsely documenting the country of origin of goods entered into the United States in order to evade quota restraints on the country of actual production. Transshipped merchandise itself will also be illegally marked with the false country of origin.
Instances have been reported where merchandise has entered the U.S. with counterfeit or fraudulent textile visas or has been produced using child or forced (slave) labor. U.S. Customs has now focused its enforcement efforts on preventing these illegal shipments of textiles and apparel.
G-III Apparel Group, Ltd. (Here in after "G-III Apparel Group") has never engaged in, or condoned, this form of illegal activity. In fact it is against G-III Apparel Group's policy to engage in any form of illegal activity. G-III Apparel Group is strengthening its efforts to assure compliance with this policy as it pertains to transshipping and similar illegal activities. The Company intends to make every effort to assure the integrity of all documents it receives and the authenticity of its sources of supply. Additionally, G-III Apparel Group will act to stop and prevent any illegal activity. If a vendor has knowledge of activity by another vendor, supplier or fellow associate which appears to be illegal, the vendor must immediately report that information to G-III Apparel Group.
If a vendor is found to have participated in, or had knowledge of any illegal activity including labor violations, transshipment or quota in any form:
1. G-III's affiliation with that vendor will be immediately terminated; and 1. All available information including the name of the vendor may be turned over to the United States Customs Service and other applicable state and federal agencies.
G-III Apparel Group considers this issue to be a serious matter. We request that you as a G-III Apparel Group vendor certificate this letter has been read, understood and agreed to as provided below.
If you have any questions concerning specific transactions, please communicate with the G-III overseas representative or contact G-III Apparel Group's Import Department in New York. Thank you in advance for your cooperation.
Respectfully,
I am a vendor/factory of G-III Apparel and certify that this letter has been read, understood and agreed to by me.
______Date Name of Factory Vendor
______Signature Print Name & Title