California Transparency in
Supply Chains Act Disclosure

California Transparency in Supply Chains Act Disclosure

In accordance with the California Transparency in Supply Chains Act of 2010, this disclosure outlines the efforts undertaken to address risks of human trafficking and forced labor within our supply chain.

 

Verification of Supply Chains

We maintain standards for supply chain participants through our Code of Conduct, which is based on internationally recognized human rights and labor principles, including standards addressing forced labor, child labor, discrimination, remuneration, working hours, and freedom of association. As part of our responsible sourcing approach, we seek to identify, prevent, and mitigate potential adverse human rights impacts within our supply chain through riskbased due diligence processes. These efforts include assessing risks related to geographic location, industry sector, and business operations.

 

Audits of Suppliers

Compliance with the Code of Conduct may be assessed through social and environmental audits conducted either by internal resources or by independent thirdparty auditors. Audits may be announced or unannounced and are conducted in accordance with recognized social compliance standards. Supply chain participants are required to provide access to facilities, documentation, and personnel for purposes of monitoring compliance.

 

Supplier Certification

We require supply chain participants to comply with all applicable laws governing labor and employment practices, including laws addressing forced labor and human trafficking. Compliance with the Code of Conduct — including its prohibition on forced labor, child labor, and human trafficking — is a condition of doing business, and suppliers are expected to uphold these standards throughout their operations and supply chains.

 

Internal Accountability

We maintain accountability mechanisms for addressing noncompliance with our Code of Conduct. Where violations are identified, we expect supply chain participants to implement corrective action plans within a reasonable timeframe. Persistent or serious noncompliance, including failure to remedy identified violations, may result in escalation measures up to and including termination of the business relationship, where appropriate.

 

Training

We expect supply chain participants to ensure that management and employees receive appropriate training and communication regarding ethical conduct, labor standards, and human rights obligations, including those related to forced labor and human trafficking. Internally, relevant personnel involved in sourcing and supply chain oversight are supported through responsible purchasing practices and ongoing awareness of social compliance expectations.