January 1, 2012 Deadline for Large Companies Doing Business in California to Publicly Disclose Efforts To Eradicate Slavery and Human Trafficking in Supply Chain

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The California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code § 1714.43 and Cal. Rev. & Tax. Code § 19547.5) (the "Act"), requires retail sellers and manufacturers doing business in California and having annual worldwide gross receipts that exceed $100 million to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. Effective January 1, 2012, a covered entity must post disclosures on its Internet website (or if it does not have a website, disclose in response to a consumer request), to what extent, if any, that the retail seller or manufacturer does each of the following:

• Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure must specify if the verification was not conducted by a third party.

• Conducts audits of suppliers to evaluate supplier compliance with company standards against trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

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