California Transparency In Supply Chains Act
Notice of Compliance with California Transparency in Supply Chains Act of 2010
As of January 1, 2012, JPUSA has been required by the California Transparency in Supply Chains Act of 2010 to disclose its efforts to eradicate forced labor and human trafficking. In September 2009 the United States Department of Labor released a report by the Trafficking Victims Protection Reauthorization Acts of 2005 and 2008 which named 122 goods from 58 countries that are believed to be produced by forced labor or child labor in violation of international standards. The Act is consistent with JPUSA’s existing Group Code of Conduct and Group Charter of Corporate Behavior. The Act allows consumers to make purchasing decisions by distinguishing companies on the merits of their efforts to supply products free from the taint of forced labor and trafficking. In compliance with the Act, and to educate our customers, JPUSA has adopted the following policies:
Supplier Audits & Certifications
JPUSA annually notifies all existing suppliers of the provisions of the Act, requiring its direct suppliers to expressly certify that they are compliant with the Act’s provisions. Our executive risk & legal management team at a minimum, on an annual basis, assesses whether to require additional verification and evaluation for specific suppliers to ensure strict compliance with the Act, and to maintain our policy of strict compliance with all applicable local laws. The decision whether or not to require additional verification may include consideration of the following factors, among other relevant facts: review of data pertaining to a supplier’s location, reported history of use of forced labor, a supplier’s use of labor brokers, list of goods identified by federal governmental authorities as being susceptible to the use of forced labor, and human rights data and other information published by non-governmental organizations. It is our policy not to transact business with suppliers who are not fully compliant.
Internal Accountability & Corporate Social Responsibility
JPUSA requires its management executives, employees and suppliers to be fully compliant with its Group Code of Conduct and its Group Charter of Corporate Behavior, which are consistent with our existing policies regarding corporate social responsibility. Such policies include compliance with the Act’s general policy of educating the Company’s customers about our efforts to eradicate forced labor, child labor and human trafficking in compliance with the Act’s requirements. All new suppliers are initially screened for compliance with the Act, and annually thereafter they are subject to the Company’s audit and verification practices. To affirm and enforce our compliance efforts, the Company requires its suppliers to contractually agree to purchase order provisions requiring strict compliance at all times with the Act. The Company may decline to transact business with suppliers who refuse to expressly certify that they are compliant.
Risk Management & Controls
JPUSA makes available annually and on an on-going basis legal and policy awareness and risk management training for management and those employees who are directly responsible for maintaining and managing its supply chain relationships. Noncompliant employees and contractors are subject to discipline and/or termination by the Company.