Razor USA LLC (“Razor”) is committed to conducting all business lawfully and with integrity. Razor’s commitment to and expectations for ensuring that our supply chain is maintained in a lawful and socially responsible way includes, among other things, that our suppliers not use forced labor in any of its forms, including human trafficking and slavery, to produce the products they provide to Razor.
This statement explains the steps that Razor has taken to prevent, detect, and respond to slavery in our business and throughout our supply chain. The statement has been prepared pursuant to the California Transparency in Supply Chains Act and the UK Modern Slavery Act 2015, as amended (the “Act”).
Our Business and Standards
Razor has been the worldwide leader in scooters since 2000, when we revolutionized the kick scooter. Since then, our brand has brought innovation to electric scooters and skateboards, hoverboards, ride-on products such as the Crazy Cart, and other youth sport and lifestyle products. We continue to grow and innovate as a trusted industry leader.
Razor’s compliance and ethics expectations are established by our policies, customers’ codes of conduct, contracts, and compliance standards, as well as in training and other communications we provide to our own personnel engaged in supply chain activities, our suppliers, and other third parties. We support suppliers who employ workers who have voluntarily and freely chosen employment and are free to leave upon reasonable notice. We source from suppliers that do not use forced, bonded, indentured labor, or involuntary prison labor. This means excluding from Razor’s supply chain any suppliers from transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.
Our Structure
Razor’s global headquarters is in Cerritos, California. Razor USA sells its products worldwide and is affiliated with Razor China, a wholly foreign-owned entity (WFOE) organized under the laws of China. Razor designs and perfects its products in the United States and China and sources most of its products from independent Chinese suppliers.
Supply Chains and Audits
Razor’s business relies on other businesses from which we purchase materials, goods, and services. Those businesses also have suppliers, forming extended supply chains for our products.
Razor sources its products from independent suppliers located in China, which build products to the high standards of Razor USA and Razor China.
Razor also performs due diligence in its business to identify and mitigate risks related to slavery and human trafficking. Razor arranges for third-party audits of all its first-tier suppliers. The audits include extensive review and questioning to ensure that there is no human trafficking or slavery or forced labor. The scope of the supplier audits includes Razor’s standards regarding forced labor, as well as broader social responsibility and sustainability policies. The audits are scheduled. In the event an audit reveals supplier non-conformance with our standards, depending on the circumstances, we would either require that suppliers establish corrective action plans and report on the implementation of such plans, or we would terminate the relationship with that supplier.
Direct Supplier Certification
While many of our commercial agreements require supplier compliance with applicable laws and regulations, Razor does not have a direct supplier certification process specifically focused on human trafficking and slavery. Razor requires that suppliers comply with our policies and/or third-party compliance standards and sustainability guidelines for suppliers, which prohibit any coerced labor.
Accountability Standards
Non-compliance with our standards regarding human trafficking and slavery – whether by a supplier or an employee – will result in corrective action, up to and including termination of the relationship, depending on the circumstances. Auditors and business representatives would work with suppliers, employees, and possibly third-party resources to resolve any instances of non-compliance. Razor promotes numerous avenues for reporting compliance concerns, including to Razor’s top legal and human resources personnel and in training modules. Such concerns are objectively investigated under the guidance and direction of our compliance or legal departments. Razor prohibits retaliation against anyone who, in good faith, raises a concern.
Training on Human Trafficking & Slavery
Razor provides mandatory training to those employees who are directly responsible for human resources, procurement, and supply chain management on the subjects of human trafficking and slavery, particularly with respect to mitigating risks within the supply chain. These employees receive training on Razor policies and procedures designed to support a supply chain free of any type of coerced labor and on the methods available for reporting concerns.
Risk Assessment and Management
Razor implements audit and employee training programs, described above, to assess and manage risks related to slavery and human trafficking in its supply chains as well as within the company.
Verification
Other than the steps and practices described above, Razor does not have a separate, comprehensive verification process for evaluating and addressing the risks of human trafficking and slavery.
In Conclusion
Razor strives to uphold the highest ethical standards in our business and for our suppliers, to ensure the elimination of modern slavery and human trafficking worldwide. We do not use persons who are held in modern slavery or trafficked, nor will we accept suppliers who use these persons.
Brent Engle
Chief Financial Officer
Date: October 20, 2022
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