CA Supply Chains Act
California’s Civil Code section 1714.43 (California Transparency in Supply Chains Act of 2010) requires manufacturers, like Xerium, and retailers to provide consumers with information regarding their efforts in preventing slavery and human trafficking in their supply chains. To this end, the law directs Xerium to inform the public as to how it addresses the following issues:
- Supply Chain Verification: Xerium does not take any independent steps on behalf of itself or through third parties to evaluate and address risks of human trafficking and slavery in its product supply chains.
- Supplier Audits: At this time, as Xerium does not have any specific company standard with respect to trafficking and slavery in supply chains, Xerium cannot evaluate supplier compliance with such standards or conduct independent, unannounced audits.
- Direct Supplier Certification: At this time, Xerium does not require its direct suppliers to certify that materials incorporated into the products Xerium buys comply with the laws regarding slavery and human trafficking of the country or countries in which Xerium’s suppliers are doing business.
- Internal Accountability Standards: Xerium has a Code of Conduct that requires its employees, directors and officers to comply with all laws, which would include slavery and human trafficking, but those laws are not specifically called out. Unless required by the terms of their engagement, contractors are not directly obligated by Xerium’s Code of Conduct. In accordance with its Code of Conduct, Xerium expects its employees, officers and directors to act ethically and this would extend to such person’s actions in the event they had knowledge of any human trafficking or slavery within Xerium’s supply chain.
- Training: Currently, Xerium does not train its employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery.