LEGAL DISCLOSURES UNDER THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will go into effect in the State of California requiring manufacturers to publicly disclose their efforts to eradicate human trafficking and slavery from their direct supply chains.
Ghirardelli mandates that all vendors, including their designated manufacturing facilities and any third parties involved with any aspect of the manufacturing process, maintain the highest level of ethical behavior to support our commitment to Corporate Social Responsibility.
Our suppliers are aware of our commitment to conduct business in a lawful and ethical manner and our expectation for our suppliers to do the same. Our Supplier Code of Conduct states, "Suppliers shall comply with all applicable national and international laws and regulations, including the International Labour Organization (the "ILO") and the United Nations' Universal Declaration of Human Rights, industry standards, and all other relevant statutory requirements whichever requirements impose the highest standards of conduct." All Ghirardelli Suppliers are required to annually document their conformance to our policy and we take a risk-based approach to direct our social auditing resources to the areas of higher risk.
In compliance with California Transparency in Supply Chains Act of 2010 (SB 657), Ghirardelli states the following:
- Ghirardelli engages in verification of suppliers to evaluate and address various risks, including but not limited to human trafficking and slavery.
- Ghirardelli has the right to audit all suppliers for compliance with our Supplier Code of Conduct. Ghirardelli employs an independent third party to audit and evaluate our suppliers' compliance with our Supplier Code of Conduct, including monitoring each supplier's compliance with all applicable labor laws governing forced labor, slavery and human trafficking.
- Ghirardelli requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking.
- Ghirardelli has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Ghirardelli's disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Ghirardelli employees involved in any similar misconduct.
- Ghirardelli will provide training on human trafficking and slavery to company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chain of products.
Ghirardelli will continue to maintain our accountability standards regarding ethical conduct and move quickly to remedy any conduct we find objectionable. By taking these steps, we believe that Ghirardelli is showing its commitment to the global effort to eliminate slavery and human trafficking.