This Statement discusses the activities of Juul Labs, Inc. and its consolidated subsidiaries (collectively, “Juul Labs”) to address forced labour, human trafficking and slavery (collectively, “modern slavery”) in our business and supply chains. We have published this Statement pursuant to both the California Transparency in Supply Chains Act and the UK Modern Slavery Act.
It continues to be a priority for Juul Labs to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This Statement describes the compliance activities and planned enhancements of Juul Labs taken as a whole since we maintain the same modern slavery compliance policies and procedures across our business despite not all of the entities in our consolidated group being subject to the California Transparency in Supply Chains Act and the UK Modern Slavery Act.
Juul Labs is a manufacturer of electronic nicotine delivery systems. Juul Labs’ mission is to transition the world’s billion adult smokers away from combustible cigarettes, eliminate their use, and combat underage usage of our products. Juul Labs’ products are targeted at adult cigarette smokers in the United States, Canada, the UK and Kuwait.
Juul Labs’ primary facilities are located in California, Washington DC and the United Kingdom. Our workforce consists almost entirely of engineers and office support personnel. Given the nature of Juul Labs’ workforce, we believe that the risk of modern slavery in our business is negligible.
We have appropriate policies in place that underpin our commitment to combat modern slavery and human trafficking in our supply chains or in any part of our business, particularly in our Child and Forced Labour Policy POL-00116.
In addition, our Partner Code of Conduct (https://www.juullabs.com/wp-content/uploads/2023/03/Juul-Labs-Partner-Code-of-Conduct-Update.pdf) (which is incorporated into our contracts with our foreign manufacturers and parts suppliers) and our employee Code of Conduct reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We continuously review and update all our policies.
We have in place systems to:
Juul Labs has zero tolerance to slavery and human trafficking and, consistent with our commitment to quality, we have a limited number of primary vendors, and our relationships with these vendors are stable and ongoing. Juul Labs’ hardware products are manufactured on its behalf by a small number of large, well-known global contract manufacturers, primarily in their factories in eastern China. The liquid in our refillable pods is manufactured in the United States by well-known, established manufacturers. We also have specified some of the tier-2 suppliers used by our contract manufacturers. We believe that the strength of our primary vendor relationships helps mitigate the risk of modern slavery in our supply chains.
Furthermore, we strive to conduct business with vendors who adhere to ethical business practices. Our vendor contracts and standard form purchase order terms and conditions include provisions that require our contract manufacturers and other vendors to comply with all applicable laws. This includes laws that prohibit modern slavery. Our contracts with our designated tier-2 suppliers also require them to comply with the law. Compliance with contractual requirements is taken into account in our procurement decisions.
Juul Labs maintains an Ethics Hotline through which employees, vendor personnel and other third parties may anonymously report violations. To make a report to the Ethics Hotline, visit www.JuulLabs.ethicspoint.com or call 0800 890011 and, at the prompt, dial 844-681-1090. We also have a Compliance Reporting, Investigations and Anti-Retaliation Policy POL-00120 which protects whistleblowers and places an obligation on Juul Labs personnel to report any violations or suspected violations of the policy through the available reporting channels.
Juul Labs is in the process of updating our Code of Conduct to explicitly address modern slavery and other labour practices. We also are enhancing our vendor due diligence and taking measures to strengthen our social compliance program to mitigate modern slavery risk in our supply chains.
Melissa Wisdom
Director, JUUL Labs UK Limited