FASHION ACT

In January, New York unveiled its proposed Fashion Sustainability and Social Accountability Act
(or Fashion Act). The law aims to hold major brands accountable for their environmental and
social impact. If passed, the Fashion Act would require retailers and manufacturers that do
business in New York, with global revenues in excess of $100 million, to disclose comprehensive
information about their environmental and social due diligence policies.

The bill would require companies:

• to provide information on raw materials used for finished goods, including if sourced from
  areas with reported forced or child labor;
• to disclose how they conducted their due diligence with respect to the environmental and
  social impacts of their practices (due diligence information would be submitted in a Social
  and Environmental Sustainability Report);
• to disclose median wages of workers for suppliers identified as a risk to environmental or
  social principles (and to compare such wages to local minimum wages).
  All of the above would be disclosed on an annual basis.
  The New York Attorney General’s Office is called to enforce the bill – which will mean the power
  to levy penalties and pursue injunctions. The bill requires the Attorney General to publish a list
  of non-compliant companies, giving them three months to become compliant, or face fines of up
  to 2% of annual revenue.

Contacting Pavia & Harcourt LLP

Questions regarding matters discussed in this publication or any other Labor & Employment
matters may be directed to Giovanni Spinelli at gspinelli@pavialaw.com or Nicolo’ Majnoni at
nmajnoni@pavialaw.com.

About Pavia & Harcourt LLP

Established in 1951, Pavia & Harcourt LLP is a business law firm concentrating in international
commercial and corporate transactions, banking, media and entertainment, real estate, litigation
and arbitration, intellectual property, estate planning and administration, and matrimonial law. We
are based in New York City.

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