TRANSPARENCY IN SUPPLY CHAIN STATEMENT

Hills Point Industries, LLC dba Gorilla Commerce (“Gorilla”) believes in applying and maintaining ethical practices in all aspects of our business. We expect our suppliers to share in those values.

As part of this mission, and in accordance with the California Transparency in Supply Chains Act of 2010 (SB 657) that went into effect in California on January 1, 2012, we believe in providing our customers with an overview of the steps we take regarding our efforts to address the issues of slavery and human trafficking. Below is a description of the policies in place related to these matters.

 Steps we take:

  • Verification – We work to identify and conduct business with suppliers and vendors who share in our values and who comply with local labor laws. The verification process does not employ a third party.
  • Audit – Audits by Gorilla employees or other representatives may be conducted in the facilities of our suppliers. Our audit efforts are a combination of independent and non-independent actions and are not unannounced.
  • Certification – Potential direct suppliers complete a qualifying questionnaire that includes questions pertaining to child and forced labor and human trafficking questions as part of our supplier risk analysis.
  • Internal Accountability – We maintain internal accountability regarding employees and contractors who fail to meet Gorilla’s anti-slavery and human trafficking standards. Each employee, contractor acting on our behalf, and supplier is responsible for adhering to these standards and applicable laws. Compliance is a condition of employment or continued relationship. A supplier’s failure to correct any violation may result in the termination of the contractual relationship between the supplier and Gorilla.
  • Training – Employees and management who have direct responsibility for supply chain management are made aware of and trained in this policy and our internal accountability standards. We may require certain employees to engage in continued training or refresher courses as part of their employment obligations.

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