California Transparency in Supply Chains Act Disclosure
Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) requires large manufacturers and retailers that sell goods in California to make certain disclosures regarding their efforts to address slavery and human trafficking. The Act is intended to ensure that retail manufactures and sellers are thinking about their efforts to eradicate slavery and human trafficking from their supply chains.
American Biltrite Inc. and its subsidiaries (collectively, “ABI”, “we”, or “our”) believe in the importance of international labor and human rights standards. As a company policy, we do not knowingly employ, or trade with partners who employ, slaves or trafficked persons.
Pursuant to the requirements of California Transparency in Supply Chains Act, the Company hereby discloses the extent to which it does each of the following:
(1) Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
The Company does engage in verification of product supply chains to the extent it reviews facilities of major suppliers as discussed in (2) below, and in its requirement that suppliers comply with all applicable laws and other legal requirements as stated in (3) below. It does not seek verification specifically to evaluate human trafficking and slavery law compliance of it vendors.
(2) Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
The Company reserves the right to verify our supplier’s compliance with applicable laws. The Company does audit some of its suppliers to evaluate supplier compliance with various laws and ability to meet product standards. In addition, the Company performs social compliance audits when required by the Company’s customers to assure supplier compliance with standards of those customers. These audits are not performed by independent auditors and they are not unannounced.
(3) Requires a direct supplier to certify that materials incorporated into a product comply with slavery and human trafficking laws in the country or countries in which that supplier is doing business.
The Company currently does require in its terms and conditions of purchase from suppliers that suppliers comply with all applicable laws in the production and supply of material purchased. Specific certification is not currently required.
(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Should the Company be made aware of any violation of law by an employee or supplier in the production and supply of material purchased, the Company would have the right to terminate any such employee or supplier agreement.
(5) 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.
The Company has in place policies requiring its employees to comply with all applicable laws. This requirement would apply to laws on human trafficking and slavery. The Company does not provide training specific to mitigating risks of human trafficking and slavery within the supply chains of products