CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010 (SB 657) DISCLOSURE
TeufelHunden Investment Group (TIG) is committed to upholding human and labor rights, ensuring that every worker has safe and fair working conditions and that there is ‘zero tolerance’ for human trafficking and slavery in our supply chain. The policies, procedures and operations outlined in our Sustainable Innovation Program incorporates explicit prohibition of human trafficking and slavery and addresses issues of human trafficking and slavery required under the California Transparency in Supply Chains Act, as well as addressing other issues of social and environmental sustainability. Standards for workplace conditions for our supply chain partners are outlined in our Code of Conduct and the code element Forced Labor specifically calls out our commitment to prohibiting human trafficking and slavery anywhere in our direct and indirect supply chain.
Below is our disclosure statement pursuant to the California Transparency in Supply Chains Act (SB 657).
The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, the supplier or partner does each of the following:
1. Verification of supply chains to evaluate and address risks of human trafficking and slavery.
TIG is currently piloting labor standards, auditing protocol and the creation of a shared database of audit results via the Fair Factories Clearinghouse (FFC). Our Code of Conduct is based on the International Labour Organization (ILO) code and states that any form of forced labor, which includes human trafficking, slavery and child labor are prohibited in our supply chain.
2. Audits of partners to evaluate supplier compliance with TIG’s standards for trafficking and slavery in supply chains.
TIG has created both Code of Conduct and Zero Tolerance policies for labor practices and implemented a process for consistent and ongoing auditing of its supply chain to ensure compliance with those policies. Proposed new partners must undergo auditing and evaluation of their facilities and labor practices before they may be considered to become a formal partner. Evaluation of those audits is conducted by senior leadership. Proposed partners unable to meet our standards will not be considered to participate in our supply chain. This system ensures that we do not contract with new partners engaging in substandard human rights practices. Auditing partners with regard to sustainable business practices, specifically slavery and human trafficking, is a priority for TIG. Audits are conducted through a combination of internal staff, contract labor consultants and third-party auditing firms.
3. Certification by partners that materials comply with slavery and human trafficking laws of the country where they are doing business.
A key focus of our communication strategy with our partners is in building a clear understanding of the risks of non-compliance with our code of conduct, especially around the topics of human trafficking and slavery. Our goal is to build capacity with our partners so that they may certify their own partners and verify the eradication of human trafficking and slavery further up complex supply webs. Partners are required to acknowledge their understanding of our Code of Conduct by formerly signing a document confirming the partner’s adherence to its requirements. In addition, we regularly evaluate a partner’s practices of managing for eradication of human rights and slavery and include that evaluation in our partner scorecards.
4. Procedures for failures to meet TIG’s standards regarding slavery and human trafficking.
TIG has internal policies & procedures that incorporate disciplinary actions appropriate to the issue at hand with separate tracks for the evaluation of new partners and the evaluation of existing partners. The focus is on remediation and executing swift solutions for the protection of human rights as well as excluding new partners from our supply chain who fail to meet our Code of Conduct and Zero Tolerance Policy. Our Zero Tolerance policy outlines a swift and binding course of action, requiring immediate response and remediation of the identified issue by those in question. Issues TIG strictly prohibits, condemns and has zero tolerance for must be given the highest level of attention and immediate resolution or TIG reserves the right to cease business with that partner.
5. Training on human trafficking and slavery, including mitigating risks within the supply chain.
TIG has an ongoing internal training program for employees to understand the issues relating to social and environmental responsibility with a focus on human trafficking and slavery in operations. This training is also extended to partners with a long-term partnership approach to remediating issues in conflict with our Code of Conduct in the supply chain. We understand that accountability is key to an authentic commitment to sustainable business. TIG’s corporate policy for sustainable operations has been communicated throughout the company, its supply chain and informs the ongoing work being carried out in product creation.
Required Disclosures
Companies subject to the Transparency in Supply Chains Act must disclose the extent of their efforts in five areas: verification, audits, certification, internal accountability, and training. Specifically, in its supply chains disclosure, a company must disclose to what extent, if any, it:
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.
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.