California Transparency in Supply Chains Act of 2010 (SB 657)
The California Transparency in Supply Chains Act, which was signed into law in October 2010 and went into effect in January 2012, requires companies in the retailer and manufacturing sectors with revenues of 100 million or more per year to disclose their initiatives to eradicate slavery and human trafficking from their direct supply chains. Though Sea & Summit is exempt from this requirement because we are a small company, we fully believe in the eradication of forced labor, slavery and human trafficking. As a result, we are taking steps now to ensure these concerns do not arise within our supply chain. The disclosure statement below provides information on how Sea & Summit is taking steps to fulfil these requirements.
Below is our disclosure statement pursuant to the California Transparency in Supply Chains Act (SB 657). Disclosure of Sea & Summit pursuant to SB 657:
The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, that the retail seller or manufacturer 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.
Sea & Summit believes in running a responsible and transparent business. This includes having a zero tolerance mentality regarding any form of forced labor, including slavery and human trafficking in our supply chain. Should this concern ever materialize in our supply chain, the factories must immediately remediate the issue or risk termination of our business relationship permanently; this is non-negotiable.
Because we are a new company, we are at the beginning stages of all of this; but we have to start somewhere. Right now, Sea & Summit is taking action in this 1st stage. We have contracted Sundowner Sustainability, to work with our manufacturer, Raining Rose Inc, to dig into our supply chain and engage our suppliers. This is going to take some time for several reasons. (1) Sea & Summit is a small grassroots company with no corporate influence; not yet anyway. While our certified organic manufacturer has ensured we are purchasing sustainable organic ingredients, they are also in the preliminary stages of making sure they only do business with socially responsible and environmentally sustainable farms; they’re already a little ahead of us.
We like this because we know our values and visions are inline and we can grow together as partners. Sea & Summit has made it clear that our business relationship is contingent upon achieving these goals. (2) Right now, our ingredients are coming from multiple organic farms around the world. So, we have decided to look into one ingredient and its’ suppliers at a time, instead of multiple ingredients at one time. We feel this will enable Sea & Summit to concentrate more on each ingredient source and not overwhelm or discourage any business or farm from working with us and sharing all their information and practices. (3) The processes of looking into, analyzing, and tracing sources to their origin, and practices of farms and factories, costs thousands of dollars, usually about 10-15k per product. We are starting with what we have, which isn’t a lot being new to the market; but we’ll get there. Sea & Summit stands behind this. We will keep you informed through our website and social media of each ingredient and our progress. Once we get all the information we need for one ingredient, we’ll move it into stage two below, and move another ingredient into stage one.
As you will see from reading the steps below, many of these requirements will take time to accomplish and will take place as Sea & Summit grows, but we’ll get there.
(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.
(3) Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
(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.
Citations:
California Transparency in Supply Chains Act (CTA)
http://www.dol.gov/ilab/child-forced-labor/California-Transparency-in-Supply-Chains-Act.htm
CTA Senate Bill (No. 657) Law Language, Full Text
http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_0651-0700/sb_657_bill_20100930_chaptered.pdf
Compliance is Not Enough: Best Practices in Responding to The California Transparency in Supply Chains Act
http://www.verite.org/sites/default/files/VTE_WhitePaper_California_Bill657FINAL5.pdf
Contending Forced Labor, Human Trafficking and Slavery: An Employer’s Handbook
US State Department, Office To Monitor and Combat Trafficking in Persons 2015 Trafficking in Person Report
http://www.state.gov/j/tip/index.htm
Fact Sheet: Human Trafficking & Where To Report Human Trafficking in the U.S.
http://www.acf.hhs.gov/programs/orr/resource/fact-sheet-human-trafficking
If you think you have come into contact with a victim of human trafficking, call the National Human Trafficking Resource Center at 1.888.373.7888. The NHTRC can help you identify and coordinate with local organizations that protect and serve trafficking victims.
Fair Labor Association (FLA) - Information On Fairtrade and How To Become a Member