Effective Date: January 1, 2026
1. INTRODUCTION
This statement outlines Antonio Venucci Global LLC’s (“Donna Vanni”) commitment to ethical,
transparent, and humannrights–aligned supplynchain practices. It is prepared in alignment with:
• California Transparency in Supply Chains Act (SB 657)
• UK Modern Slavery Act 2015 (Section 54)
• Global ethicalnsourcing standards

2. OUR COMMITMENT
Donna Vanni has zero tolerance for:
• Forced labor
• Child labor
• Human trafficking
• Coerced or unpaid labor
• Unsafe or abusive working conditions
We require all suppliers, subcontractors, and manufacturing partners to adhere to lawful, safe, and
ethical labor practices.

3. SUPPLIER VERIFICATION & RISK ASSESSMENT
We evaluate suppliers before onboarding through:
• Documentation review of labor practices
• Supplier certifications (where applicable)
• Thirdnparty audits (when available)
• Compliance questionnaires
We assess geographic, operational, and materialnlevel risks.

4. AUDITS
As a growing luxury brand, we conduct:
• Internal reviews of supplier documentation
• Occasional site visits (where feasible)
• Monitoring through independent audit reports when provided
We reserve the right to perform unannounced audits or require thirdnparty verification.

5. SUPPLIER CERTIFICATION
All suppliers must certify that:
• Their operations comply with local labor and wage laws
• No forced or trafficked labor is used
• Subcontractors also comply with these standards
• They maintain transparent worker records and conditions

6. INTERNAL ACCOUNTABILITY
Employees managing sourcing and procurement receive training about:
• Modern slavery risks
• Ethical sourcing expectations
• Recognizing red flags in supply chains
Violations by employees or suppliers result in disciplinary action or termination of the relationship.

7. TRAINING
Donna Vanni trains relevant staff on:
• Identifying forced labor and trafficking indicators
• Reviewing supplier documentation
• Escalation processes for concerns
Training improves as the company scales and adds new suppliers.

8. CORRECTIVE ACTION
If we discover a supplier violating ethical-labor expectations, we will:
• Investigate promptly
• Require immediate remediation
• Suspend or terminate the supplier relationship if issues persist
• Support corrective measures to protect workers

9. PRODUCT TRACEABILITY
We strive toward greater supplynchain traceability. As the brand grows, we will:
• Increase documentation requirements
• Map deeper tiers of the supply chain
• Expand audit coverage
Traceability is a long-term commitment aligned with luxurynindustry expectations.

10. PUBLIC TRANSPARENCY
This statement:
• Is published on donnavanni.com
• Will be updated annually
• Reflects our ongoing responsibility to ethical sourcing

11. REPORTING CONCERNS
If you suspect unethical labor practices in our supply chain, contact:
ethics@donnavanni.com
We investigate all credible reports and act swiftly.

12. BOARD/OWNER APPROVAL
This statement is approved by Antonio Venucci Global LLC leadership and reflects the company’s
position on supplynchain ethics.