THE CALIFORNIA SUPPLY CHAIN TRANSPARENCY ACT OF 2010 - SB 657 Disclosure
The California Transparency in Supply Chains Act of 2010 took effect on January 1, 2012 with the goal of ensuring that companies provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains. CamelBak supports this goal and expects its suppliers and manufacturers to uphold fundamental labor and human rights standards in the workplace.
CAMELBAK: OUR SUPPLY CHAINS AND HOW WE WORK
The products we build come from supply chains around the globe. CamelBak manufactures products in our wholly-owned ISO-certified factory, as well as with time-tested supply and manufacturing partners (each a "Supplier" and collectively the "Suppliers"). While foreign laws and regulations govern working conditions for overseas Suppliers, we also expect them to comply with our own Code of Conduct, which specifically outlines policies against any type of slave labor, human trafficking, child labor, forced or indentured slavery and any other form of discrimination. We employ the following policies and procedures to implement our Code of Conduct and uphold our zero tolerance policy toward slavery and human trafficking:
- Our contracts specify that Suppliers must comply with our Code of Conduct in order to do business with CamelBak, and we require a senior level executive of the Supplier to sign a form acknowledging such compliance. Suppliers failing to meet our Code of Conduct would be in breach of our agreement. We also maintain on-site staff with certain Suppliers, and members of our in-house staff regularly visit Supplier locations to verify compliance and monitor production and working conditions. Our Code of Conduct is posted at large overseas Supplier locations, both in English and in the native country language. Employees of Suppliers are given access to an anonymous tip line (that is also available to CamelBak employees) to allow for reporting of violations of the Code of Conduct. We take human rights violations seriously, and CamelBak reserves the right to terminate its business relationship with any Supplier that violates our Code of Conduct.
- CamelBak utilizes an industry-recognized third party service to conduct thorough audits of overseas Suppliers, announced or un-announced, to observe and verify labor practices and compliance with our Code of Conduct. These visits include monitoring of labor documentation, health and safety issues, fire and regulation standards and confidential personal interviews with Supplier employees. Annual audit results are reviewed by the Sourcing Department and the Vice President of Operations. Any failures are addressed directly with the factory and corrective action measures taken based on the audit results. CamelBak reserves the right to terminate its business relationship with any Supplier that has failed to comply, regulate or improve health, safety, human rights or violations of any kind.
- CamelBak requires Suppliers to certify that they have completed an online training course on the subject of human trafficking as provided by the US Department of Homeland security to ensure that they understand what human trafficking is, how to recognize it, and what steps to take in the event of a violation. Suppliers are also required to share this training with their supply chain partners to ensure compliance throughout the supply chain. CamelBak requires Suppliers to certify that materials incorporated into our products comply with the laws regarding human trafficking and slavery of the country or countries in which they are doing business.
- CamelBak maintains internal accountability standards and procedures for our employees and contractors in our Code of Conduct. All CamelBak employees receive training on our Code of Conduct. Failure by an employee or contractor to follow the standards set forth in the Code of Conduct may subject such person to disciplinary action up to and including termination of employment.
- All CamelBak employees with direct responsibility for supply chain management undergo an online training course on trafficking and forced labor issues provided by the United States Department of Homeland Security.