The California Transparency in Supply Chains Act of 2010 (The “Act”)
The California Transparency in Supply Chains Act requires companies subject to the Act to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains. The purpose of the Act aligns with one of NYDJ's core beliefs – that the community of consumers should be empowered to make better and more informed purchasing decisions by knowing which companies have active social-responsibility programs. There are five topics contemplated by the Act. Here is how NYDJ is addressing each one:
- Verification / Risk Assessment – NYDJ is committed to fair labor practices in its supply chains. We use an independent third-party monitor to assist in assessing the risk of human trafficking and slavery by direct suppliers in our supply chains. The independent monitor's evaluation is based on many factors, including the supplier's geographic location and manufacturing processes, its workforce profile, and the history of human trafficking in the supplier's sector. NYDJ keeps a record of the results of all assessments and follows up with suppliers regarding any recommendations from the independent monitor. For direct suppliers located in the United States, we conduct such assessments prior to our initial order and then no less than once each calendar quarter. For direct suppliers located outside the United States, we conduct such assessments prior to our initial order and then no less than once each year.
- Supplier Audits – NYDJ conducts audits of its direct suppliers to evaluate compliance with company standards and policies related to the avoidance of slavery and human trafficking. The audits are conducted by a third-party auditor and are sometimes announced and sometimes unannounced. For our direct suppliers located in the United States, we conduct such audits prior to our initial order and then no less than once each calendar quarter. For our direct suppliers located outside the United States, we conduct such audits prior to our initial order and then no less than once each year.
- Supplier Certification – NYDJ requires that its direct suppliers certify in writing annually that their goods comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. We also require that our direct suppliers maintain records sufficient to substantiate compliance with such applicable laws.
- Internal Accountability – NYDJ maintains internal accountability standards and procedures for employees or contractors failing to meet NYDJ's standards regarding slavery and trafficking. Non-compliance can result in corrective action or termination, depending on the severity and frequency of non-compliance.
- Training – NYDJ requires that all employees who have direct responsibility for supply-chain management undergo training regarding NYDJ's policies, practices and procedures that are designed to ensure that our supply chains are free of any type of human trafficking or slavery. All new employees that have direct responsibility for supply-chain management are required to complete such training within their first 100 days of employment, and all such employees must receive certification of completion.