Compliance Deadline Looms For New Transparency in Supply Chains Act

Sheppard Mullin Richter & Hampton LLP
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On Jan. 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will become effective. This legislation will require every large retailer and manufacturer doing business in California to publicly disclose to what extent it: evaluates the risk of slavery and human trafficking in its product supply chain, and whether the evaluation is conducted by a third party; audits its suppliers, and whether the audits are independent and unannounced; requires direct suppliers to certify that materials incorporated into the product comply with applicable laws regarding slavery and human trafficking; holds employees and suppliers accountable; and trains employees on mitigating the risk of slavery and human trafficking in the product supply chain. California Civil Code Section 1714.43(a).

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