Responding to a stated concern over human trafficking and goods that are produced by forced or child labor, the California Legislature passed the California Transparency in Supply Chains Act of 2010 with the goal of “ensur[ing] large retailers and manufacturers provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains.”1 This is the first state or federal law of its kind. Beginning January 1, 2012, every retailer and manufacturer doing business in California with annual worldwide gross receipts exceeding $100 million must conspicuously disclose on its website the extent to which it does the following:

1. Engages in third-party verification of its supply chains to evaluate and address the risk of trafficking and forced labor;

2. Conducts independent, unannounced audits of its suppliers to evaluate their compliance with company standards for trafficking and forced labor in its supply chains;

3. Requires suppliers to certify that materials incorporated into the product comply with local laws on trafficking and forced labor;

4. Maintains internal accountability standards and procedures for employees and contractors failing to meet company standards regarding trafficking and forced labor;

5. Provides training on trafficking and forced labor issues to employees with direct responsibility for supply chain management.