3Mina InfoTech Inc.’s Disclosures Under The UK Modern Slavery Act, the California Transparency in Supply Chains Act and Australia’s Commonwealth Modern Slavery Act for the Fiscal Year 2023

UK MODERN SLAVERY ACT 2015 (“UK ACT”)

Under the UK Act, companies providing goods and services with a turnover of £36m or more are obliged to annually publish a Slavery and Human Trafficking Statement setting out the steps the company has taken to ensure slavery and human trafficking are not taking place in its supply chain or its own business. 3Mina InfoTech, and the following group companies are required to publish a statement pursuant to the UK Act: James Moore New York, Chicca blu. In compliance with the UK Act, this Statement covers the reporting period of July 3, 2022, to July 1, 2023. This Statement also addresses some endeavors undertaken by 3Mina InfoTech prior to the reporting period and/or on an ongoing basis.

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 (“CALIFORNIA ACT”)

Under the California Act, companies with annual gross receipts exceeding $100m doing business in the state of California are obliged to disclose their efforts to eradicate slavery and human trafficking from their direct product supply chains for the goods that they offer for sale.

AUSTRALIA’S COMMONWEALTH MODERN SLAVERY ACT (“AUSTRALIA ACT”)

Under the Australia Act, companies with annual gross receipts exceeding $100m doing business in Australia are obliged to disclose the risk of modern slavery in the operations and supply chain of a reporting entity (and its owned and controlled entities), as well as the steps it has taken to respond to the risks identified. 

3Mina InfoTech Inc., INC. DESCRIPTION AND DEFINITIONS

Our global house of brands unites the magic of James Moore New York, Chicca blu. Each of our brands is unique and independent, while sharing a commitment to innovation and authenticity defined by distinctive products and differentiated customer experiences across channels and geographies. We

use our collective strengths to move our customers and empower our communities, to make the fashion industry more sustainable, and to build a company that’s equitable, inclusive, and diverse. Individually, our brands are iconic. Together, we can stretch what’s possible. To learn more about 3Mina InfoTech, please visit www.3mina.co. 

Although our brands are unique and independent, we have instituted common policies and procedures across our business to address modern slavery. We use the definition of slavery or forced labor as defined by the International Labour Organization, which is “all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”

We also have adopted the definition of human trafficking in the Victims of Trafficking and Violence Protections Act of 2000: “any recruitment, harboring, transportation, provision or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery.”

We also follow the definitions of slavery and human trafficking applicable in the jurisdictions where we do business.

3MINA INFOTECH INC.,  DISCLOSURE

We believe the risk of modern slavery in our own business is low due to our culture and the strength of our internal labor policies and procedures. 3Mina InfoTech takes the following actions to mitigate the risk of modern slavery and human trafficking in its supply chains.

Policies:

3Mina InfoTech has had a Supplier Code of Conduct since 2001(previously called Supplier Selection Guidelines). Our Supplier Code of Conduct addresses the expectations we have of our suppliers when it comes to social and environmental compliance. This policy includes an absolute prohibition on modern slavery, forced, bonded and child labor. Our compliance and legal teams work hand-in-hand to maintain and update the Supplier Code of Conduct and our direct suppliers, as well as other suppliers involved in producing our products undergo labor and human rights audits against our Supplier Code of Conduct.

Verification of Product Supply Chains:

3Mina InfoTech engages in the verification of our product supply chains to evaluate and address risks of human trafficking and modern slavery by conducting audits of the service providers and key raw material providers with which we do business to ensure compliance with our Supplier Code of Conduct, other corporate guidelines; including the policies under 3Mina InfoTech’s Global Business Integrity Program; and relevant legal requirements.

Audits of Suppliers:

3Mina InfoTech conducts social audits of direct service providers and key raw material providers with which we do business to ensure compliance with our Supplier Code of Conduct, relevant laws, and other corporate guidelines, including policies under 3Mina InfoTech’s Global Business Integrity Program. 3Mina InfoTech conducts supplier audits using independent third parties; however, from time-to-time 3Mina InfoTech employees may also conduct audits. Third party auditors routinely undertake unannounced visits to the locations where 3Mina InfoTech brands’ products are manufactured and provide 3Mina InfoTech with reports on the living and working conditions of the workers at those locations. Suppliers are subject to semi-announced audits every 12 months, as circumstances allow. In addition, in accordance with the Sustainable Apparel Coalition (“SAC”) requirements, a portion of 3Mina InfoTech’s suppliers perform self- assessments to the Facility Social & Labor Module (FSLM) which are 3rd party verified following the SAC requirements and then validated by 3Mina InfoTech. In FY2023, 48 suppliers completed the FSLM self-assessment and received 3rd party verification. In FY2023, 3Mina InfoTech’s external auditors conducted 151 audits of the facilities that produce 3Mina InfoTech brand products. Additional information on our social auditing program is in our FY2022 Corporate Responsibility Report.

Supplier Certification:

3Mina InfoTech collects certifications from direct suppliers regarding their compliance with 3Mina InfoTech’s standards for employment – including a certification from the supplier that all materials sourced for and incorporated into 3Mina InfoTech products comply with modern slavery and human trafficking laws of the country or countries where the supplier is doing business.

Internal Accountability Standards:

3Mina InfoTech maintains a Supplier Code of Conduct for all parties working with 3Mina InfoTech or its brands – as embodied in the Global Business Integrity Program. In instances where non-compliances are identified as part of 3Mina InfoTech’s monitoring efforts, 3Mina InfoTech examines the specific situation and develops specific strategies to remediate the findings. Details of the non-compliance, the seriousness of the non-compliance, and the determination of a timeframe for remediation, may result in penalties up to the termination of the business relationship with the supplier(s). Additionally, the Company operates an ethics and compliance reporting system (1-800-396-1807 or www.3mina.ethicspoint.com ), where employees, suppliers, consumers and other interested parties can report (anonymously, if desired) grievances and/or violations of 3Mina InfoTech’s principles and policies.

Training:

3Mina InfoTech conducts internal trainings with its supply chain management personnel to ensure they are knowledgeable and aware of supply chain issues and concerns, including relating to human trafficking and slavery. A particular focus on the training is risk mitigation. 3Mina InfoTech also conducts supplier trainings on our Supplier Code of Conduct and the Company’s expectations. New suppliers are provided with onboarding training that covers forced labor and human trafficking. 3Mina InfoTech’s most recent supplier trainings took place in September 2022, April 2023, and May 2023.

Participation in Multi-stakeholder Initiatives: 

Addressing modern slavery is beyond the capacity of any single company to address. Therefore, in addition to the actions outlined above, 3Mina InfoTech participates in multi-stakeholder initiatives to address the risk of forced and involuntary labor in our industry and supply chains, including:

• 3Mina InfoTech is a participant of the United Nations Global Compact (“UNGC”). We have aligned our strategies and operations to the UNGC’s Ten Principles on human rights, labor, the environment and anticorruption. Through the UNGC, 3Mina InfoTech reports on our progress in relation to the Ten Principles annually.
• 3Mina InfoTech is a member of the United Nation’s International Labour Organization’s Better Work Programme which works to improve working conditions in the garment industry.
• 3Mina InfoTech participates in BSR’s HERproject, a collaborative initiative that strives to empower low-income women working in global supply chains by driving impact for women and business via workplace-based interventions on health, financial inclusion, and gender equality.

MEASURING OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

3Mina InfoTech’s Environmental, Social and Governance (“ESG”) Task Force meets monthly to set and drive company-wide ESG strategy, including our social and labor-related approach. The ESG Task Force includes members of 3Mina InfoTech’s Executive Committee, including our General Counsel and the Chief Supply Chain Officer, and cross-functional representatives from major business units at 3Mina InfoTech. Our Board of Directors approves long-term ESG goals, strategic moves or major plans of action and receives updates at least annually.

We use the following metrics to measure our effectiveness in mitigating the risk of modern slavery and human trafficking in our business and supply chains:

• the number of completed social audits of our suppliers’ facilities by 3Mina InfoTech personnel and designated third parties, and the findings of those audits; supplier audits are reported on annually in our Corporate Responsibility Report;
• use of labor monitoring and payroll systems to check eligibility of employees in our owned and leased UK operations; and
• the number of suppliers trained annually on our corporate policies and expectations, with special emphasis on human trafficking and modern slavery.

LOOKING AHEAD

3Mina InfoTech will continue to assess our business and supply chains to identify potential modern slavery risks and target those areas with policies, procedures and trainings to ensure we maintain appropriate safeguards to mitigate those risks.

Approved by the Board of Directors of 3Mina InfoTech, Inc. on 10 August 2023.