The California Transparency in Supply Chains Act of 2010 – S.B. 657
The California Transparency in Supply Chains Act (the “TSCA”) require certain companies in California to publicly disclose their efforts to eradicate slavery and human trafficking from their direct supply chain for goods offered for sale.
Chicken of the Sea International stresses and supports ethical procurement in its entire supply chain. This applies not only to the raw materials and fisheries it sources from, but very importantly, to the entire supply chain process including the manufacturing of its products. Below, we describe some of the actions we have taken to ensure that workers in our supply chain are freely employed and assured their basic rights.
Supplier Standards
Our Supplier Code of Ethics includes provisions on labor and human rights, including specific reference to each worker’s right to freely chosen employment. We strictly prohibit forced, bonded, indentured, or involuntary prison labor. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. We prohibit any use of slavery or human trafficking in our supply chain, and are required to take reasonable precautions to ensure that its own suppliers do not engage in these practices.
As part of our Supplier Code of Ethics, Chicken of the Sea requires its direct suppliers to ensure that the materials they use in the products they produce for us comply with all applicable laws on slavery and human trafficking. While there is currently no official “slavery-free” certification – and indeed it may be technically impossible to guarantee that second and third tier suppliers are in total compliance – suppliers are expected to take reasonable and proactive measures to minimize risk of slavery and human trafficking throughout their supply chain and eradicate it in places that it is found to exist.
Vendor Evaluation
We have a robust vendor evaluation process that applies to all suppliers that provide inputs to our product and its packaging. The evaluation looks at issues of quality, capacity, compliance, and good business practices. In 2012, we will be expanding this evaluation to specifically include aspects of labor and human rights – including slavery and human trafficking.
Audits and Verification
Chicken of the Sea currently works with independent auditors, who make announced and unannounced visits at supplier facilities that provide material inputs to our products. To date, these audits have focused mainly on quality, compliance, and health and safety, and good business practices. In 2012, we will expand the audit process to also include specific criteria on environmental responsibility, labor practices, and human rights – including slavery and human trafficking.
As a first step, we will map our supply chain to identify product and regions that may be more susceptible to forced labor, slavery, and human trafficking issues. Vendors operating in these areas will receive additional scrutiny in 2012, with a complete roll-out to all vendor audits in 2013.
Second, we will work with our audit team to create an evaluation process based on compliance with international best practice on labor practices and human rights and the Chicken of the Sea Supplier Code of Ethics. We will create a compliance reporting framework to capture issues of noncompliance and remediation actions. This framework will allow us to more accurately spot patterns and risks of slavery and human trafficking, which will improve our vendor evaluation and selection process over time.
Employee Training
As of January 2012, Chicken of the Sea is requiring all of its management and any employees who are responsible for supply chain management to undertake an online training course on Human Trafficking and Slavery Risks, designed specifically for supply chain professionals. The training focuses on presenting real-world scenarios to help participants identify both the obvious and more subtle indicators of trafficking or forced labor, and how to take appropriate actions necessary to mitigate the risk of slavery and human trafficking
Noncompliance and Remediation
Chicken of the Sea will not tolerate any supplier or employee that does not comply with the law as well as our standards regarding slavery or human trafficking. Failure to comply with our policy and standards will require that supplier to be removed as an approved supplier and they will be reported to the appropriate authorities. The Company will not source from them until they are in complete compliance with those policies.
Continuous Improvement
Chicken of the Sea is committed to work closely with its suppliers and others in the industry to help raise awareness and also take appropriate steps to eradicate slavery and human trafficking. We are constantly seeking to improve our sourcing practices and are currently undertaking major sustainability projects with independent consultants in order to improve the entire product supply chain and reduce our overall impact on the environment and society.