California Transparency in Supply Chains Act and Forced Labor in Canadian Supply Chains Disclosure
On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. On January 1, 2024, Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) came into effect. The underlying purpose of these laws is to educate consumers, so they can make informed decisions and purchase goods from companies that responsibly manage their supply chains.
This report describing the activities of Boll & Branch LLC (“Boll & Branch”), a Delaware limited liability company, covers the period between January 1, 2024 and December 31, 2024.
Boll & Branch is a leading designer and retailer of luxury home textiles, including cotton sheets, towels, bedding, pillows, mattresses, and bedroom furniture. Boll & Branch ships goods across the United States and Canada to consumers who order such goods from Boll & Branch’s website, www.bollandbranch.com. Boll & Branch also has numerous retail locations across the United States.
Boll & Branch was founded on the belief that every person in its supply chain is entitled to fair wages and a safe working environment. From its inception in 2014, Boll & Branch has identified the risk of exploited workers across the bedding industry, the vendors that make up its supply chain, and the raw materials used to create its products. Most of Boll & Branch’s products include or are manufactured with cotton, which is procured and turned into sellable goods through its multi-tiered supply chain. Boll & Branch’s primary supply chain consists of the farmers/ginners (responsible for growing and procuring lint cotton), spinners and weavers (responsible for processing the lint cotton and turning it into thread and fabric), and cut and sew (responsible turning the thread and fabric into finished goods). Specifically, Boll & Branch has identified the agricultural and manufacturing industries as carrying the highest potential risk of forced labor or child labor being used.
To prevent and reduce these identified risks, Boll & Branch holds itself and its vendors accountable to high ethical standards by embedding responsible business conduct into its internal policies and vendor management systems. As a mitigation step, Boll & Branch requires its vendors to be engaged in a fully transparent and efficient cotton fiber procurement process. Additionally, vendors must ensure their suppliers and subcontractors meet Boll & Branch’s quality, integrity, and supply needs.
Boll & Branch works tirelessly to ensure its products are produced ethically by its vendors across its entire supply chain in accordance with the Boll & Branch Vendor Manual (the “Vendor Manual”), the terms of which are incorporated into its vendor agreements. The Vendor Manual, which specifically prohibits the use of forced and child labor, contains a Vendor Code of Conduct and addresses certain compliance information, including supply chain traceability, materials procurement, audits, and sustainability. Boll & Branch’s Production & Compliance Team, either on its own or through a third-party, routinely audits its supply chain, including all of its vendors and their subcontractors, for ethical, social, and labor practices. Prior to engaging with a new vendor, or before the start of a new program and/or product, the Vendor Manual dictates that Boll & Branch’s Production & Compliance Team must review and approve each vendor’s supply chain.
In addition to its internal diligence processes, Boll & Branch also works with a number of third-party certification or assessment organizations to add accountability to its practices and to ensure the individuals crafting its products are paid and treated fairly. Boll & Branch holds and/or requires its vendors to hold the following relevant certifications:
- Global Organic Textile Standard (the worldwide leading textile processing standard for organic fibers that incorporates fair treatment and pay for workers);
- Fair Trade Certified (sets standards to promote safe working conditions and improved livelihood for farmers and factory workers in developing nations);
- SA8000 (helps secure ethical working conditions for millions of workers globally);
- Worldwide Responsible Accredited Production (promotes safe, lawful, humane, and ethical manufacturing); and
- Use of third-party auditor HireAPartner (a supply chain compliance platform that assists Boll & Branch in meeting legal requirements and adhering to the Boll & Branch Vendor Manual) or Smeta 4-Pillar Ethical Audit (relating to Labor Standards, Health & Safety, Environment, and Business Ethics).
To maintain these certifications and/or comply with the relevant requirements of these programs, relevant Boll & Branch employees, including the members of the Production & Compliance Team, engage in appropriate training about the risks of forced labor and how to mitigate such risks through Boll & Branch’s business practices.
In an effort to remediate the loss of income and other harms that workers have suffered as a result of forced and child labor, Boll & Branch pays a fair trade premium for a number of the products and services it procures. These premiums go directly to factory workers, who spend the money as they see fit. Boll & Branch also ensures its processes, including in the farming of its organic cotton, are free from toxins to ensure there is a safe environment for its farmers and factory workers.
Boll & Branch is committed to open communication relating to its supply chain. See, https://www.bollandbranch.com/pages/our-impact/. It regularly publishes “Impact Reports,” the latest of which was published in May, 2024. See, https://issuu.com/bollandbranch/docs/impactreport_final_0826. Each Impact Report informs customers and potential vendors of Boll & Branch’s standards and practices relating to the environment, its workers, and the quality of its products. In addition to its Impact Report, Boll & Branch shares traceability of its supply chains with its customers and the general public. See, e.g., https://www.bollandbranch.com/pages/10-year-anniversary/.
As its business and supply chain evolves, Boll & Branch will continue to update its policies and procedures applicable to its supply chain.
In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.
Scott Tannen
Founder & CEO
April 29, 2025
14435402.2