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California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 became effective January 1, 2012 (the “Act”) and requires retailers and manufacturers doing business in California to disclose actions and efforts, if any, to eliminate slavery and human trafficking from their direct supply chains. 


At BOLD Swim. (“BOLD Swim”), we are committed to ethical business practices and social responsibility. We do not condone or knowingly support forced labor, and shall continue to make efforts to ensure this is reflected in our supply chain and in the partners with whom we engage. 


To comply with requirements of the Act, we are disclosing the following information:

1. Risk Assessments. BOLD Swim performs assessments of suppliers on various risk factors, including suppliers’ labor practices and reputation. For BOLD Swim branded products, we attempt to visit most of the facilities in which our branded products are made to ensure the suppliers’ quality and operational practices meet BOLD Swim standards and may during such process, assess certain labor conditions. 


2. Auditing. Our supplier contracts require compliance with all applicable laws, which includes laws relating to labor, slavery and human trafficking. Generally, we require our suppliers confirm that a third-party independent auditor has audited their manufacturing facilities to ensure they meet industry standards, including certain labor related practices, and make available to us any corresponding audit report for our review. For our BOLD Swim branded products we may audit our supplier facilities ourselves or with assistance from third-party auditors from time to time, and during such audits, we may assess labor related practices.  


3. Certification Requirements. In addition to requiring suppliers to contractually represent that they comply with all applicable laws, BOLD Swim also sells certain products which have third-party certifications, such as Fair Trade Certified , Certified Organic that have various certification requirements such as banning child and forced labor. BOLD Swim does not separately require suppliers to provide any additional certification about human trafficking and forced labor. 


4. Internal Accountability. BOLD Swim is committed to social responsibility and ethical conduct in the workplace. While our employee handbook does not specifically mention human trafficking or forced labor, we consider our requirements that each employee comply with the law and conduct business in a fair and transparent manner as including a prohibition against human trafficking, coerced labor and slavery. Any employee’s failure to comply with the BOLD Swim employee handbook may result in disciplinary action. 


5. Training. Currently, we do not provide any specific training for BOLD Swim personnel responsible for supply chain management with respect to the Act, and the topics covered therein. However, we continually assess all of our policies and procedures, including training practices, and update such materials when opportunities may arise.