SUPPLY CHAIN TRANSPARENCY ACT
Introduction
This statement is made pursuant to the California Transparency in Supply Chains Act of 2010, which requires retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their direct supply chain.ba&sh recognizes its responsibility to respect human rights across all of its activities and its value chain, a commitment formalized in the following documents.
Business
BA&SH US, Inc. ("ba&sh US") is a subsidiary of BA&SH SAS, which is owned by Muse Holding ("Muse").ba&sh US distributes premium apparel, accessories, and fashion products on behalf of BA&SH to customers throughout the United States, including the State of California.
ba&sh US Purchases:
• Ready-to-wear apparel, footwear, handbags, and accessories from BA&SH SAS;
• Marketing services, communication materials, packaging, and point-of-sale materials from suppliers located in various countries, including Europe.
BA&SH SAS designs, develops, manufactures (directly or indirectly), distributes, and markets apparel, footwear, handbags, fashion jewelry, and fashion accessories under the ba&sh brand.
Key Policies
• Suppliers' Code of Conduct: sets out the commitments expected from all of ba&sh's suppliers and subcontractors regarding human rights, working conditions, health and safety, freedom of association, and environmental protection, based on the amfori BSCI framework.• Social Compliance Policy: describes ba&sh's mandatory social audit process, traceability program (via the Fairly Made platform), and supplier monitoring practices.
• Responsible Purchasing Charter: sets out, material by material, sourcing restrictions in regions at high risk of forced labor or child labor, as well as traceability requirements.
• Human Rights Policy: formalizes ba&sh's commitment to respecting human rights across its value chain, its international reference framework, governance, and due diligence processes.
1. Verification
ba&sh assesses the risks of slavery and human trafficking in its supply chain. This assessment relies on: mapping of suppliers, production sites and subcontractors down to tier 5, using the Fairly Made traceability tool (partnership since 2022); targeted sourcing restrictions in regions at high risk of forced labor and/or child labor; and a mandatory social audit process conducted by independent third parties, which serves as the central external verification mechanism (see section 2).2. Audits
ba&sh audits its suppliers. Any new supplier must provide a compliant social audit before placing a first order, conducted by an accredited independent third party using one of the following methodologies: BSCI, SMETA/SEDEX, ICS or WCA, and dated less than 24 months.If the audit rating is C or below, a follow-up audit is mandatory within 12 months. These audits are most often semi-announced, but may also be announced or unannounced.
In addition, ba&sh reserves the right, without prior notice, to verify, or have an appointed external partner verify, compliance with the Code of Conduct, and to conduct compliance audits at suppliers and their own subcontractors.
3. Certification
ba&sh does not require its direct suppliers to formally certify that materials comply with anti-slavery laws in their country of manufacture.Two mechanisms nonetheless go in this direction: the Suppliers' Code of Conduct requires each supplier to guarantee compliance with its human rights obligations, including by its own sub-suppliers; and the Responsible Purchasing Charter prohibits sourcing certain raw materials from regions identified as being at high risk of forced labor, and requires suppliers to provide, upon request, evidence of compliance (transaction certificates, certificates of origin).
4. Internal Accountability
For its suppliers, the Social Compliance Policy provides that failure to provide a mandatory social audit is considered a serious breach, resulting in the automatic termination of the commercial relationship.The Human Rights Policy specifies that in the event of confirmed child labor or forced labor at a supplier, ba&sh reserves the right to terminate the commercial relationship, in accordance with applicable law and responsible exit principles.
For its employees and service providers, governance of the Human Rights Policy is overseen by ba&sh's Executive Management and led operationally by the CSR team.
Any concern can be reported through ba&sh's customer service (https://ba-sh.com/fr/en/customer-service) or through ba&sh's whistleblowing system (https://report.whistleb.com/fr/message/bash).
5. Training
ba&sh's CSR team completes training through the Amfori BSCI social compliance platform, covering human rights risks in the supply chain more broadly.This training does not, however, specifically address the risks of modern slavery and human trafficking.
