Commitment to Universal Rights

Modern Slavery and Human Trafficking Statement

Introduction

IMS Trading, LLC, along with its affiliates and subsidiaries ("IMS Trading"), is dedicated to the eradication of modern slavery and human trafficking within its business operations and supply chain.

This statement outlines the measures IMS Trading undertakes to identify, address, and prevent acts of modern slavery and human trafficking.

Throughout the last fiscal year, IMS Trading did not encounter any incidents of modern slavery or human trafficking within its operations or supply chain.

Organizational Structure

IMS Trading, LLC is a premier small business in the United States, specializing in the manufacturing and distribution of wellness and beauty products. We offer body exfoliators and body wellness tools to a diverse clientele.

Based in Audubon, PA, IMS Trading operates primarily within the U.S. but engages with suppliers and partners both domestically and internationally.

Our supply chain includes direct to consumer, direct to retail partner distribution and partnering with various supply chain sourcing partners.

Our Policies

IMS Trading is committed to ensuring our operations and supply chains are free from modern slavery and human trafficking. Our policy reflects our responsibility to uphold ethical conduct and integrity in all business dealings along with implementing systems and controls to ensure compliance.

We regularly review our HR policies and procedures to comply with applicable laws and safeguard the rights and freedoms of all employees. This includes policies on working conditions, discrimination, health and safety, and data protection.

Risk Assessment

An annual risk assessment, both internal and external, on modern slavery and human trafficking is conducted by our Legal, Human Resources, and Finance teams.

IMS Trading acknowledges the potential risks through our third-party suppliers and our focus is on minimizing these risks through diligent supplier assessment and strong contractual commitments.

Due Diligence

IMS Trading engages with suppliers and independent producers who meet our labor and welfare standards or are committed to achieving these standards. Suppliers are selected based on their adherence to our requirements against modern slavery and human trafficking.

The due diligence and reviews include the following actions:

reviewing on a regular basis all aspects of the supply chain;
evaluating the modern slavery and human trafficking risks of each new supplier;
conducting annual assessments; and
invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate this policy, including the termination of the business relationship.

Supplier Commitments

All labor must be voluntary. Supplier shall not support or engage in slavery or human trafficking in any part of its supply chain.

Suppliers contracted by IMS Trading, and their suppliers, vendors, agents, and subcontractors and their respective facilities (the “Partners”), are required to:

Abide by all relevant laws, including those related to modern slavery and human trafficking.
Guarantee they have measures in place to prevent modern slavery and human trafficking within their operations and supply chains, including ongoing monitoring of suppliers and proper verification of and record keeping for the eligibility of all workers. IMS Trading, LLC will terminate relationships with any found to be involved in modern slavery or human trafficking.
Ensure that workers have the right to freedom of movement, including the right to leave the work facility after each workday.
Allow workers to terminate their employment or work arrangement without restrictions or discipline.

Suppliers shall not and Suppliers shall ensure that their Partners shall not support or engage in, or require any:

compelled, involuntary, or forced labor;
labor to be performed by children;
bonded labor;
indentured labor;
prison labor;
import of goods by labor of North Korean citizens or nationals; or
import of goods made with forced labor in the Xinjiang Uyghur Autonomous Region (XUAR or Xinjiang) of China.

IMS Trading shall ensure that it imports no goods which are produced by any of the above through its due diligence assessment and review of its supply chain sources.

Suppliers shall not require any worker to surrender control over original identification papers or documents, such as a passports, birth certificate or any other documents giving a worker the right to work in a certain country.

Without limiting Supplier’s obligations hereunder, Supplier shall not, whether or not as a condition to the right to work, require any worker (or worker’s spouse or family member) to, directly or indirectly incur debt or make financial guarantees.

Internal Commitments

We will take measures to train our employees, particularly those in procurement and supply chain management roles, to help them identify and assess risk within our operation and supply chain.

Identifying signs of modern slavery and human trafficking
Understanding the company's policies and procedures related to modern slavery and human trafficking
Reporting suspected cases of modern slavery and human trafficking

Employees shall also refrain from engaging in or supporting any of the Supplier restrictions stated above. IMS Trading shall ensure internal compliance through its risk assessments. Any employee that breaches the requirements of this policy will face disciplinary action, which includes dismissal.

Conclusion

IMS Trading commits to continual evaluation and enhancement of its policies, procedures, training and practices regarding modern slavery and human trafficking as ethical business conduct.

This statement reflects IMS Trading LLC’s dedication to social responsibility and ethical business practices for the fiscal year ending 2023.

Michael Ghesser

Co-CEO & COO

IMS Trading, LLC