Legal Compliance

Corporate Disclosure in Compliance with California Transparency in Supply Chains Act of 2010

Design Within Reach (DWR) strives to maintain an ethical work environment that promotes dignity and respect, and is committed to positive labor and environmental practices in its own facilities and at the facilities of its suppliers. The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California, like DWR, to disclose their efforts to eradicate slavery and human trafficking from their direct supply chain to tangible goods offered for sale. DWR makes the following disclosures, as required by the Act and, with respect to its efforts to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale, and confirms that DWR employs the following practices:

Verification

DWR’s policies and standards dictate that its suppliers refrain from the direct or indirect use of forced labor and any form of human trafficking. Suppliers are required to certify that they comply with DWR’s policies and standards.

 

Auditing

Suppliers are required to demonstrate adherence to DWR’s policies and standards prohibiting the use of forced labor and human trafficking by permitting social and environmental audits. These audits are conducted by DWR employees and independent third-party audit firms.

 

Certification

DWR requires that its suppliers agree to a Vendor’s Agreement which, among other things, requires them to comply with all applicable laws and regulations, provide a safe and sanitary workplace free from harassment and discrimination, and certify that materials incorporated into the products they supply to DWR do not come from, and that they do not and will not knowingly engage in, any forced labor, slavery or human trafficking. The Vendor's Agreement is intended to make it clear that DWR does not intend to do business with suppliers that are engaged in slavery and human trafficking.

 

Internal Accountability

DWR requires its employees to represent it, and to act at all times, in an ethical manner. DWR seeks to create and maintain internal accountability standards and procedures for employees and contractors regarding slavery and human trafficking and to make it clear that DWR does not engage in and does not intend to do business with suppliers that are engaged in slavery and human trafficking. As part of these standards and procedures, DWR will advise its employees and contractors to bring any suspected supplier issues involving slavery and human trafficking to the attention of DWR's management. Possible violations of DWR’s policy against slavery and human trafficking will be investigated and appropriate action taken, including possible termination of a violator’s relationship with DWR.

 

Training

DWR will provide periodic training for its employees and officers who have responsibility for supply chain management. This training will provide information concerning human trafficking and slavery, familiarize them with identifying slavery and human trafficking issues and address mitigating the risk of such issues within its supply chain of products.

 

Policy regarding “conflict minerals”
Why we insist on DRC Conflict Free

On August 22, 2012, the United States Securities and Exchange Commission (SEC) announced its adoption of final rules relating to “conflict minerals” under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Conflict Minerals Rules”).

 

The purpose of the Conflict Minerals Rules is to discourage the use of minerals that might be financing the violent conflict within Central Africa.

 

“Conflict minerals” are gold, Columbite-tantalite (coltan), cassiterite, wolframite or their derivatives, which are currently limited to tantalum, tin and tungsten, regardless of their source. Conflict minerals that can lead to adverse consequences under the Conflict Minerals Rules are those that originate in (or are mined from) the Democratic Republic of the Congo (DRC) or adjoining countries (Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, Sudan, Tanzania, Uganda and Zambia), known as “DRC Conflict Minerals.”

 

Design Within Reach, Inc., an affiliate of Herman Miller, Inc., is committed to operating in a socially responsible manner. It is our policy to refrain from purchasing DRC Conflict Minerals that may finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country – directly or indirectly from any sources. It is our requirement that suppliers not supply Design Within Reach with any products that the supplier cannot certify as “DRC conflict free” within the meaning of the Conflict Minerals Rules.

 

Design Within Reach requires that its suppliers establish their own due diligence programs to ensure a supply chain that results in products that are “DRC conflict free.” Suppliers must provide assurance to Design Within Reach that all products supplied to Design Within Reach or our affiliates are “DRC conflict free” in accordance with the Conflict Minerals Rules.

 

Responsible Wood Sourcing

Design Within Reach is committed to conserving, protecting and restoring natural resources. We fully support responsible forest management practices that promote ecosystem sustainability, biodiversity and long-term environmental, social and economic benefits.

 

Commitment to Sustainability

Design Within Reach is committed to being a leader in environmental sustainability, both in the way we carry out our operations and in the products we offer. For us, environmental sustainability means conducting our business in a manner that acknowledges, measures and takes responsibility for our direct and indirect impact on the environment. By developing policies to conserve energy, dispose of waste more responsibly, reduce pollutants and other byproducts, and promote sustainability, we align our long-term success with the earth’s ecological well-being and create enduring benefits for our clients, employees and the communities in which we operate.