CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010 DISCLOSURE

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INTRODUCTION

This statement is made pursuant to the California Transparency in Supply Chains Act of 2010 which requires retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their direct supply chain.  This statement sets out of the steps taken by Millionaire Fresh Inc. (collectively, “MillionaireFresh”) to ensure that slavery, servitude, forced or compulsory labor and human trafficking (collectively, “Modern Slavery”) is not taking place in any part of its business or in its supply chains.

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BUSINESS

Millionaire Fresh Inc. (“MillionaireFresh LA”) is a subsidiary of Millionaire Fresh Inc.

MillionaireFresh LA distributes premium apparel on behalf of Millionaire Fresh Inc to clients in the United States including the State of California.  Millionaire Fresh LA is among the most iconic brands worldwide and its unique positioning encompasses most high-quality product categories, such as Haute-Couture, Women Men and Children’s RTW, Leather Goods, Accessories, Shoes, and relies on exceptional savoir-faire.

Millionaire Fresh LA purchases:

1. Women Men and Children’s RTW, Leather Goods, Accessories, and Shoes from Millionaire Fresh Inc.; and

2. Marketing, packaging, and point of sale materials from suppliers located in various European countries, including France

Millionaire Fresh Inc. directly or indirectly manufactures, distributes and sells luxury Women Men ’s and Children RTW, Leather Goods, shoes and fashion accessories under the trademarks MillionaireFresh or Millionaire Fresh LA.

 

POLICIES AND PRACTICES

Millionaire Fresh LA’s commitment is to act with integrity in all its business dealings and to promote ethical conduct to enhance compliance with applicable law and to provide guidance with respect to business conduct. MillionaireFresh LA has a number of policies that are relevant to this commitment, which set out what MillionaireFresh LA expects from its employees, internal business and its external suppliers.

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Key policies are:

• MillionaireFresh LA Suppliers’ Code of Conduct (copy available upon request)

MillionaireFresh LA expects its suppliers to share its commitments and to act in full compliance with all applicable laws, including all national, local and international laws relating to the management of their businesses.

MillionaireFresh LA requires its suppliers to seek approval before subcontracting any part of their supply chain process and Millionaire Fresh LA’s approval is subject to acceptance by the subcontractor of the Suppliers’ Code of Conduct and such other conditions that Millionaire Fresh LA determines.

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• Millionaire Fresh LA Code of Conduct (copy available upon request)

The MillionaireFresh LA Code of Conduct includes relevant sections on “Honesty & Ethical Conduct”, “Compliance with Laws & Regulations”, “Safe Working Conditions” and “Sales & Commercial Transactions”.

Our anti-modern slavery policy reflects our commitment to act ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

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MillionaireFresh LA expects its employees and suppliers to engage in and promote honest and ethical conduct, comply with all applicable laws, rules, and regulations in their own area and act responsibly, with due care, competence, and diligence when dealing with colleagues, customers, suppliers, agents, and intermediaries.

The MillionaireFresh LA Code of Conduct reiterates Millionaire Fresh Inc. Code of Conduct and commitment to act with the highest standards of integrity, respect and engagement in our behaviors and in the way that we conduct business every day, everywhere.

This Code of Conduct further states that the group companies will inform all of their commercial partners of these ethical principles and expectations and will ask its suppliers to comply with the principles set out in the Suppliers’ Code of Conduct.  In particular, this code specifies compliance with social issues to abide, respect and adhere to the company's moral and ethical values in the management of the company concerning human rights, working conditions, and environmental issues.

 

 

SUPPLIER AND CONTRACTOR DUE DILIGENCE

MillionaireFresh LA has been carefully reviewing its suppliers and a lot of its suppliers are carefully chosen for the entire group by Millionaire Fresh Inc.

MillionaireFresh LA reserves the right to check adherence of its suppliers and contractors to the principles set out in the Suppliers’ Code of Conduct and to conduct compliance audits. Upon a reasonable request, MillionaireFresh LA suppliers and contractors shall supply the necessary information and grant access to MillionaireFresh LA representatives to verify compliance with the requirements of the Suppliers’ Code of Conduct.  Suppliers and contractors shall further keep proper records to provide compliance with this Code and provide access to complete, original and accurate files to MillionaireFresh LA representatives.

Upon a reasonable request, MillionaireFresh LA suppliers and contractors must improve and correct any deficiency discovered during any such audits.

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MillionaireFresh LA shall use its reasonable endeavors to ensure that all MillionaireFresh LA supplier and contractor template contracts contain clauses requiring MillionaireFresh LA’s suppliers and contractors to adopt similar anti-modern slavery standards and practices.

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TRAINING OF MillionaireFresh LA’s EMPLOYEES

MillionaireFresh LA does not at this time provide company employees and management with specific training on human trafficking and slavery.

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