PURPOSE AND SCOPE

This Statement applies to: Silver Oak Wine Cellars, LLC and all its subsidiaries, affiliates, partnerships, and joint ventures (hereinafter referred to as “Company”).

The Company is committed to respecting internationally recognized human rights throughout its global operations. Consistent with this commitment, the Company strives to prevent, identify, and eliminate modern slavery, including human trafficking, from its global operations.   

OUR CORPORATE STRUCTURE & OPERATIONS 

The Company is a Limited Liability Company (LLC), primarily operating in California. For purposes of complying with The California Transparency in Supply Chains Act, this statement constitutes the requisite disclosure for the financial year ending in 2024, and applies to the following entities: Silver Oak, Twomey and Timeless.

Among other policies, our business operations are governed by our Supplier Code of Conduct, a core value of which is respect for internationally recognized human rights and compliance with the applicable laws.   

OUR SUPPLIERS

Our suppliers with whom we have contractual relationships (“Direct Suppliers”) are generally those that provide grapes, temporary staffing, packaging materials, farm equipment, winemaking products, and paper and office supplies.  Our Direct Suppliers are located throughout the world. 

We expect our Direct Suppliers to conduct all their business transactions in a manner that respects internationally recognized human rights, and in compliance with all applicable laws, and in compliance with our Supplier Code of Conduct.  

MODERN SLAVERY RISKS

The Company is not aware of any situations in which modern slavery exists within its own operations, or in the operations of its Direct Suppliers.   

As such, and in light of the actions described below, the Company believes the risk of modern slavery is low in its operations and those of its Direct Suppliers.  

ACTIONS TAKEN TO ADDRESS MODERN SLAVERY RISKS

• Policies: Our policies, including our Supplier Code of Conduct, reflect our commitment to respecting internationally recognized human rights, and complying with all applicable laws and regulations, including those laws on modern slavery.   
• Questions and Reporting: The Company encourages all its employees, suppliers, customers and other stakeholders to report any concerns and raise any questions they may have related to the Company’s direct activities, or the supply chains of the Company.  This includes any circumstances that may give rise to an enhanced risk of modern slavery. The Company’s reporting procedure is designed to make it easy for employees to make disclosures in full confidence without fear of retaliation, including reporting to our Vice President of Human Resources, Veronica Jauregui She can be contacted my phone or email: (707) 942-7065; veronica@silveroak.com 
• Supplier Code of Conduct: Our Supplier Code of Conduct lays out twelve guiding principles the Company expects of its Direct Suppliers. This includes complying with all laws and regulations in the jurisdictions in which they operate, a commitment to eliminate forced labor, child labor and discriminatory practices, as well as establishing safe and healthy working conditions, among others. Suspected violations of the Supplier Code of Conduct must be reported immediately. 
• Accountability: If a Direct Supplier is found to be in violation of the Company’s Supplier Code of Conduct, the Company reserves the right to end the relationship with that Direct Supplier. 
• Training: Employees responsible for working with Direct Suppliers receive annual training on the Supplier Code of Conduct and ways to recognize modern slavery. 
• The Company as an Employer: The Company is committed to complying with California law and any other applicable laws and respecting the internationally recognized human rights of its employees through our internal employment policies and practices.