California Privacy Rights - Direct Marketing
If you are a California resident and a customer of Lief, LLC, you have the right to request information from Lief regarding the manner in which Lief shares certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California Civil Code § 1798.83 provides you with the right to submit a request to Lief at its designated address and receive the following information:
- The categories of personal information Lief disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
- The names and addresses of third parties that received such information; and
- If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. Lief's designated email address for such a request is email@example.com.
California Privacy Rights - California Minors
Certain areas of our Websites may contain interactive features that allow registered users to post content or information on or to our Websites (the “Interactive Services”). If any of our Interactive Services are either: (1) directed toward California residents under the age of eighteen (18); or (2) if Lief has actual knowledge that a registered user of the Interactive Services is a California resident under the age of eighteen (18), Lief will permit such registered user to remove (if applicable) or request that Lief remove or anonymize such content or information as posted by the registered user, to the extent required by California Business and Professions Code § 22581.
If you are under the age of eighteen (18) and would like to request the removal or anonymization of content or information you have posted on or to our Websites, please send your request to firstname.lastname@example.org.
California Proposition 65
The Safe Drinking Water and Toxic Enforcement Act of 1986, also referred to as Proposition 65, is a California initiative to address concerns regarding exposure to toxic chemicals. Proposition 65 requires warning labels on products that contains certain levels of the 600+ elements that the California Air Resources Board considers a carcinogen or a reproductive toxicant. These elements include lead, brass, PVC and a multitude of other everyday elements.
The general Proposition 65 notice is: WARNING: You have purchased an item that contains a chemical known to the state of California to cause cancer, birth defects or other reproductive harm.
California Transparency in Supply Chains Act
As required under the California Transparency Supply Chain Act, we are disclosing our efforts to mitigate the risk of slavery and human trafficking in our supply chain.
Lief, LLC is committed to fair labor practices throughout the supply chain. New and existing private brand contracted factories are assessed against our Workplace Standards and Code of Conduct (below) which are based on International Labour Organization standards. Assessments are initiated based on geographic location, workplace history or previous audit record and other policy requirements. These audits are performed by Lief's Managing Members and, where feasible, also by third party verifiers. Results are reviewed internally by the Managing Members to assure compliance.
Lief audits its private brand contract factories to determine if they are in compliance with our standards, which in addition to requiring compliance with local laws on working hours, wages and health and safety concerns, also prohibit forced, slave or child labor. Audits are performed by Lief's Managing Members. Annual and follow-up audit frequency is determined in accordance with our policy and is based in part on the level of risk and non-compliance determined by previous audit results.
As part of the supplier onboarding process, all vendors are required to certify to conduct business in accordance with all applicable laws and regulations which include any existing laws on slavery and human trafficking in the country of manufacture. Lack of compliance or continuous improvement after the identification of potential non-compliance may result in termination of the business relationship.
Lief's Managing Members are responsible for overseeing the compliance and factory monitoring programs. Lief's Managing Members work together to ensure that the Factory Compliance Policy is followed. In addition to requiring corrective actions and remediation of identified non-compliances, Lief encourages factories to take ownership of compliance management and implement root cause/management systems based approaches to facilitate sustainable improvement.
Lief will provide annual training to relevant associates on our Workplace Standards, Code of Conduct and program requirements. Training will be conducted with management level associates in roles related to sourcing, product development, quality assurance and who interact with or travel to factories and may be in the best position to identify issues. Training on responsible sourcing guidelines and program expectations will also be conducted in annual meetings with vendors and factories.
Lief's Workplace Standards and Code of Conduct for Vendors:
Business partners must comply fully with all legal requirements relevant to the conduct of their businesses.
Business partners must not use forced labor, whether in the form of prison labour, indentured labour, trafficked labour, bonded labour or otherwise. No employee may be compelled to work through force or intimidation of any form, or as a means of political coercion or as punishment for holding or expressing political views.
Business partners must not employ children who are less than 15 years old, or less than the age for completing compulsory education in the country of manufacture where such age is higher than 15.
Business partners must not discriminate in recruitment and employment practices. Decisions about hiring, salary, benefits, training opportunities, work assignments, advancement, discipline and termination must be based solely on ability to perform the job, rather than on the basis of personal characteristics or beliefs, such as race, national origin, gender, religion, age, disability, marital status, parental status, association membership, sexual orientation or political opinion. Additionally, business partners must implement effective measures to protect migrant employees against any form of discrimination and to provide appropriate support services that reflect their special status.
Wages & Benefits
Wages must equal or exceed the minimum wage required by law and legally mandated benefits must be provided. In addition to compensation for regular working hours, employees must be compensated for overtime hours at the rate legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate exceeding the regular hourly compensation rate.
Employees must not be required, except in extraordinary circumstances, to work more than 60 hours per week including overtime or the local legal requirement, whichever is less. Employees must be allowed at least 24 consecutive hours rest within every seven-day period, and must receive paid annual leave.
Freedom of Association & Collective Bargaining
Business partners must recognize and respect the right of employees to join and organize associations of their own choosing and to bargain collectively. Business partners must develop and fully implement mechanisms for resolving industrial disputes, including employee grievances, and ensure effective communication with employees and their representatives.
Employees must be treated with respect and dignity. No employee may be subjected to any physical, sexual, psychological or verbal harassment or abuse or to fines or penalties as a disciplinary measure. Business partners must publicize and enforce a non-retaliation policy that permits factory employees to express their concerns about workplace conditions directly to factory management or to us without fear of retribution or losing their jobs.
Health & Safety
A safe and hygienic working environment must be provided, and occupational health and safety practices which prevent accidents and injury must be promoted. This includes protection from fire, accidents and toxic substances. Lighting, heating and ventilation systems must be adequate. Employees must have access at all times to sanitary facilities which should be adequate and clean. Business partners must have health and safety policies which are clearly communicated to employees. Where residential facilities are provided to employees, the same standards apply.
Business partners must ensure they are compliant with local and national laws regarding the environment, including regulatory agency requirements designed to limit consumer exposure to harmful chemicals.