California Transparency in Supply Chains Act (SB 657)
The California Transparency in Supply Chains Act of 2010 (SB 657) requires manufacturers and retailers to disclose their efforts to eradicate slavery and human trafficking within their supply chains. This document outlines O.C. Tanner’s efforts to ensure that it avoids all direct and indirect use of forced labor and any forms of human trafficking in its supply chain.
O.C. Tanner expects all manufacturers, vendors and suppliers (individually and collectively “suppliers”) to maintain fundamental labor and human rights standards. All potential domestic and international suppliers must submit an evaluation survey before a relationship can be established with O.C. Tanner. The O.C. Tanner supplier survey directly asks if the potential supplier operates in compliance with the California Transparency in Supply Chains Act of 2010 (SB 657). Any potential supplier that fails to confirm that it is operating in accordance with the Act will be advised that it cannot become a supplier to O.C. Tanner until it is in compliance. If the supplier is selected, it is required to covenant that it will continue to operate in compliance with SB 657. Any supplier failing to meet these standards will be in breach of our agreement.
O.C. Tanner is conducting an on-going audit on all of its current domestic suppliers and is contacting each organization to document SB 657 compliance. A copy of each supplier’s response is retained in the supplier’s permanent record.
SB 657 verification and review occurs regularly with existing vendors during annual reviews and contract renewal. In addition, all purchasing managers are provided with the O.C. Tanner Supplier Assessment to utilize during supplier site visits. The O.C. Tanner Supplier Assessment is designed to assess an existing supplier’s performance and includes a specific question regarding the certification and documentation of SB 657. If a supplier cannot verify that it operates in compliance with SB 657, a specific action plan and recommendations are initiated to align the supplier with SB 657 requirements. If the supplier refuses to comply with SB 657 requirements, O.C. Tanner will end the supplier relationship.
All direct international suppliers have either documented SB657 certification on file, or received SB 657 certification via a contracted third party. An on-going factory and social audit program ensures continued compliance. In the event a direct international supplier fails an audit, blatantly violates local law, SB 657, or O.C. Tanner’s social standards, a third party audit will take place within six months of the initial review. Consultation calls and specific requirements from O.C. Tanner management are a part of the resolution process. Compliance issues will be resolved on a case-by-case basis if they arise. Improvements made during that period of time will be documented and retained. If the direct international supplier fails a second time, O.C. Tanner will end the supplier relationship.
All direct international suppliers of goods have certified that they meet these social responsibility requirements at a minimum:
- Any violation of a child labor law is not tolerated.
- The suppliers abide by minimum wage, time and overtime laws established in its respective country. Working conditions and equality standards meet guidelines set by local government authorities. This includes discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation and age.
- The supplier does not engage in or support the use of corporal punishment, mental/physical coercion or verbal abuse.
- The supplier is held to the SA8000 standard of social accountability via a third party audit, a standard for decent working conditions. SA8000 incorporates child labor, forced labor, health and safety, freedom of association, discrimination, discipline, working hours, compensation and management systems into its standard.
O.C. Tanner maintains standards and procedures for supplier evaluation and selection in the O.C. Tanner Quality Manual. As an ISO 9001:2008 certified company, O.C. Tanner is audited on a regular basis to ensure the quality manual is being adhered to within the scope of our certification.
Purchasing employees within O.C. Tanner must comply with the O.C. Tanner Quality Manual, which includes procedures that ensure business practices and supplier operations are in compliance with all applicable laws. All purchasing employees within O.C. Tanner are also required to participate in a social responsibility training class, which includes a segment on The California Transparency in Supply Chains Act of 2010.