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Companies Must Disclose Supply Chain Transparency Efforts Under California Law

Tuesday, July 14, 2015
Sandler, Travis & Rosenberg Trade Report

The California Transparency in Supply Chains Act requires certain companies to report on their specific actions to eradicate slavery and human trafficking in their supply chains.  Sandler, Travis & Rosenberg will conduct a webinar July 14 to review the requirements of this law, including the required notice, placement of the notice and topics that must be disclosed. Click here for more information or to register.

The law requires retailers and manufacturing companies with worldwide annual revenues of $100 million or more to disclose on their websites their initiatives to eradicate slavery and human trafficking from their direct supply chains for the goods offered for sale.  A company must disclose to what extent it (1) engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery, (2) conducts audits of suppliers, (3) requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the countries in which they are doing business, (4) maintains accountability standards and procedures for employees or contractors that fail to meet company standards regarding slavery and human trafficking, and (5) provides employees and management  training on slavery and human trafficking. 

The law requires all covered businesses make the required disclosures, even if they do little or nothing at all to safeguard their supply chains. However, businesses are not required to implement new measures to ensure that their supply chains are free from human trafficking and slavery or to reveal confidential, proprietary and/or trade secret information.

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