California Transparency In Supply Chains Act Disclosure
On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. As a result, many companies (above a certain size) manufacturing or selling products in California are required to disclose their efforts (if any) to address the issues of human trafficking and slavery, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.
JC Whitney and its subsidiaries (collectively, "JC Whitney") strive to achieve and maintain high standards of corporate integrity and ethical behavior. JC Whitney and its employees adhere to the JC Whitney Code of Ethics and Business Conduct (the Code). JC Whitney expects that its suppliers will conduct their businesses not only in a lawful manner but also in compliance with the same high standards of integrity and ethics. JC Whitney expects that its suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business. JC Whitney suppliers are further expected to take reasonable and necessary steps to help ensure that their sub-contractors and sub-suppliers conduct business in compliance with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business. Suppliers are expected to promptly take corrective action to address any deficiencies identified with respect to compliance with the laws regarding anti-slavery and anti-human trafficking. If a supplier is found to be in violation of the laws regarding anti-slavery and anti-human trafficking JC Whitney reserves the right to terminate its relationship with that supplier for failure to comply. JC Whitney employees and management who have direct responsibility for supply chain management regularly visit and inspect its suppliers facilities to further ensure compliance with laws regarding anti-slavery and anti-human trafficking. JC Whitney participates in industry groups to share experiences and gain new information to improve compliance in its supply chain. JC Whitney has zero tolerance for slavery, human trafficking and child labor.
VERIFICATION: JC Whitney currently does not verify its suppliers in its supply chain to evaluate and address risks of slavery and human trafficking. JC Whitney does not conduct third party verification of its suppliers, compliance with anti-slavery and anti-human trafficking laws. However, JC Whitney utilizes its internal resources to regularly visit and inspect its suppliers, places of business to ensure compliance with anti-slavery and anti-human trafficking laws.
AUDITS: JC Whitney currently does not conduct independent and unannounced formal audits of its suppliers to evaluate compliance with JC Whitney standards for anti-slavery and anti-human trafficking in its supply chain. However, JC Whitney utilizes its internal resources to regularly visit and inspect its suppliers, places of business to ensure compliance with anti-slavery and anti-human trafficking laws.
CERTIFICATIONS: JC Whitney does not require all of its suppliers to provide any certifications regarding compliance with anti-slavery and anti-human trafficking laws of the country or countries in which they are doing business. However, JC Whitney expects that its suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business.
ACCOUNTABILITY: JC Whitney expects its employees, whose duties involve the JC Whitney supply chain, to comply with all applicable laws and regulations relating to anti-human trafficking and anti-slavery. JC Whitney takes the issues of slavery and human trafficking very seriously and will continue doing its part by responsibly managing its supply chains in an effort to eradicate human trafficking and slavery. All reports of alleged violations will be investigated by JC Whitney. If the results of an investigation indicates that corrective action is required, JC Whitney will decide the appropriate steps to take, including discipline, dismissal, and possible legal proceedings. Disregard or deliberate ignorance of the law is not tolerated and may lead to disciplinary action.
TRAINING: JC Whitney requires annual certification from our employees that they understand and will adhere to the Code. JC Whitney is in the process of conducting awareness training on anti-slavery and anti-human trafficking for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within its supply chain.
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