The California Transparency in Supply Chains Act of 2010 (SB 657), Civil Code Section 1714.43 (the “Act”), is intended “to ensure large retailers and manufacturers provide consumers with information regarding their efforts to eradicate slavery and human trafficking from the supply chains, to educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains, and, thereby, improve the lives of victims of slavery and human trafficking.”
Rea Magnet Wire Company (“Rea”), including its subsidiaries, does not tolerate slavery or human trafficking in its operations or its suppliers’ operations. Rea expects its suppliers to comply with applicable laws, including laws against forced or involuntary labor.
The Act requires disclosure of actions being taken in five areas. The following is Rea’s disclosure in each area:
Verifications. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Rea does not engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Rea monitors its suppliers informally and visits some supplier sites and, in the event of discovery of evidence of human trafficking or slavery, would take appropriate remedial actions.
Audits. Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. Rea does not conduct audits of its suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains. Rea monitors its suppliers informally and visits some supplier sites and, in the event of discovery of evidence of human trafficking or slavery, would take appropriate remedial actions.
Certifications. Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Rea does not require 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. Rea’s standard terms and conditions of purchase and its agreement templates for use with strategic suppliers require compliance with applicable laws.
Accountability. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. Rea’s applicable standards include: Rea’s Code of Ethics which states Rea’s commitment to compliance with laws, including those pertaining to forced labor, sets forth policies and procedures for reporting and addressing violations, issues, and concerns, and requires employees to periodically acknowledge understanding of the Code and the obligation to report known or suspected violations of law or the Code.
Training. Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Rea currently does not provide training specific to human trafficking and slavery to company employees and management who have direct responsibility for supply chain management. Rea, however, has contracted with WeComply to provide online compliance-related training.
This disclosure applies to Rea’s subsidiaries subject to the California Transparency in Supply Chains Act of 2010.
