California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act (SB 657), effective January 1, 2012, requires companies to report on specific actions taken to eradicate slavery and human trafficking in their supply chain. Your company must report if it meets these three criteria:
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Your company files its California taxes as a retailer or manufacturer.
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Your company does business in California as defined in the California Revenue and Taxation Code.
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Your company earns more than $100 million in worldwide gross receipts
You should seek legal counsel to determine if SB 657 applies to your company.
If SB 657 applies to your company, it must report on five specific points and to what extent, if any, you engage in these. You can remember the five points using the acronym, VACIT. UL-STR Responsible Sourcing can help you with your reporting requirements.
Verification: Do you engage in third-party verification; have you identified the risk of slavery and human trafficking in your supply chain?
UL-STR Responsible Sourcing provides third-party verification. Our customized supply chain mapping and comprehensive risk services identify existing risks related to human trafficking, slavery and other labor issues, such as child and migrant labor.
Auditing: Do you engage in independent, unannounced auditing to check on adherence to your company standards on slavery and human trafficking?
UL-STR Responsible Sourcing has conducted social compliance audits for nearly 20 years in over 140 countries. We can help ensure your social audits go far enough to verify compliance with local and international laws on slavery and human trafficking, including assessments of recruitment processes.
Certification: Do you require your direct suppliers to certify that the materials incorporated into your product comply with the local laws on slavery and human trafficking?
Our online Labor and Employment Standards Library, LESLi, is a comprehensive, online labor law database containing national legislation on forced labor and human trafficking. Additionally, our staff is prepared to help you develop tailored policy language on the topic for your contractual agreements with suppliers.
Internal accountability: Are you holding your employees and contractors accountable to your company standards on slavery and human trafficking?
To assess the capacity of your internal policies and procedures related to human trafficking, UL-STR Responsible Sourcing can conduct an in-depth systems gap analysis and make recommendations for compliance.
Training: Do you train your employees directly responsible for supply chain management on mitigating the risk of slavery and human trafficking in your supply chain?
Our team has comprehensive training materials on the risk of forced labor and human trafficking in supply chains. Training can be delivered in person or via the Web in over 30 languages.
“Complying with The California Transparency in Supply Chains Act,” published in the August 2011 issue of Compliance & Ethics Professional, provides an in-depth discussion of The Act, who is impacted, and what steps companies can take to prepare for public disclosure. Our Insights into The California Transparency in Supply Chains Act provides valuable information and resources on the issues of slavery and human trafficking.