California Transparency in Supply Chains Act

To ensure that our suppliers and contractors respect and enforce our company standards, we include a contract clause in our commercial agreements with suppliers that stipulates that our suppliers must abide by our antislavery and human-trafficking standards. Thus, as a condition of doing business, suppliers must self-certify that (1) they comply with all applicable laws and regulations regarding the eradication of forced labor, human trafficking, and slavery; (2) their supply chains and materials comply with national and international laws that prohibit human trafficking and slavery; and (3) they agree to conduct business in compliance with all applicable labor laws. Our company requires each supplier and contractor to maintain records that are sufficiently detailed to substantiate that all materials supplied to us are produced in compliance with the human-trafficking and antislavery laws of the country or countries where they are produced. This includes records regarding proof of age for workers, employee records and timesheets, written documentation of the terms and conditions of employment, local health and safety evaluations, exemptions from any applicable laws, and records of employee grievances. These records must be produced to company auditors upon request. We also use independent country, commodity, and product risk data, which is provided by a global risk advisory firm, to score, rank, and evaluate the human trafficking risks associated with what we buy and where we buy it. The results help us decide whether direct suppliers should complete a self-assessment or whether an independent audit is justified.