2012 CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB 657) (THE “ACT”)

The Act, which became effective January 1, 2012, requires certain retail sellers and manufacturers to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. It is intended to provide consumers with the means to determine which companies have an active social responsibility program and thereafter to make conscientious purchasing decisions.

The points outlined below highlight the Act’s mandatory disclosures, followed by an explanation of how the company is addressing each of them

  1. Verification – The company continues to develop monitoring systems to assess and ensure Associate’s compliance with the slavery and human trafficking prohibitions set forth in the Code through various means, including, but not limited to, independent, unannounced on-site third party verification visits.
  2. Audits – The company relies on independent third party vendors to conduct unannounced audits of Associates, which assist in the evaluation of Associates’ compliance with Company’s supply chain standards for trafficking and slavery.
  3. Integrity of Components – By executing the Code, every Associate certifies that materials incorporated into goods and merchandise manufactured for the Company comply with labor and trafficking laws, and with all other applicable laws, rules and regulations of the respective country or countries in which they do business.
  4. Accountability – Associates must manifest their commitment to the implementation of the Code’s stated anti-slavery and human trafficking principles by maintaining or establishing an appropriate management system (with adequate documentation and record-keeping in place) to address compliance with these principles and detection and correction of any non-compliance.
  5. Training – In connection with its commitment to enforce and uphold the principles set forth in the Code, the Company provides training on recognizing the warning signs of human trafficking and slavery to those employees who have direct responsibility for supply chain management.