The California Transparency in Supply Chains Act of 2010 (the “Act”) requires certain retailers and manufacturers doing business in California to provide information regarding their efforts to eliminate slavery and human trafficking in their supply chains. In compliance with the Act, this statement is provided on behalf of Michelman, Inc. (“Michelman”).
Michelman is committed to the highest standards of lawful, honest, and ethical conduct in all business dealings. This commitment is reflected in various policies and practices maintained by Michelman, including those contained in its Code of Business Conduct.
Verification. Michelman purchases products, components and raw materials from suppliers located in the United States and in foreign countries. Michelman generally verifies its supply chains by doing business with suppliers that are well-established, reputable organizations that respect the legal requirements of the jurisdictions in which they operate. Michelman believes that its suppliers do not engage in illegal slavery or human trafficking, but does not otherwise engage in verification of, or engage third parties to verify, product supply chains to evaluate and address the risks of slavery or human trafficking.
Audits. Michelman expects all of its suppliers to comply at all times with all applicable laws and to engage in honest and ethical business conduct. Michelman would take prompt action if it found evidence that a supplier was engaging in any illegal activity, including slavery or human trafficking. Except as discussed above regarding verification, however, Michelman does not conduct audits of its suppliers to evaluate compliance with Michelman’s standards regarding slavery and trafficking in supply chains.
Certifications. As discussed above, Michelman does business with reputable suppliers that, to its knowledge, are in compliance with the legal requirements of the jurisdictions in which they operate and that Michelman believes operate in a legal, honest, and ethical manner. Michelman does not require direct suppliers to certify that materials incorporated into its products comply with the laws regarding slavery and human trafficking of the country or countries in which they do business.
Accountability. Michelman follows, and requires all employees to follow, policies that demand lawful, honest, and ethical conduct in every aspect of business dealings, including a Code of Business Conduct that includes the requirement to comply with all laws and regulations of the United States and the other countries in which Michelman does business. Violation of these policies may result in disciplinary action, up to and including termination of employment, or other legal action as appropriate.
Training. Except as stated above regarding Accountability, Michelman does not currently provide employees and management, who have direct responsibility for supply chain management, with training on slavery and human trafficking, including with respect to mitigating risks within the supply chains of products.