The California Transparency in Supply Chains Act of 2010 (SB 657) was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts to address the issue of slavery and human trafficking in their direct supply chain. This information allows consumers to make better, more-informed choices regarding the products they buy and the companies they choose to support.
At Johns Manville (JM), we believe that workers at our facilities as well as those of our direct suppliers have the right to freely choose employment. It is our policy not to purchase materials that have been produced with slave, forced or child labor or labor that has resulted from human trafficking. Accordingly, JM is taking the following efforts regarding SB 657 and our supply chain in general:
1. Verification of product supply chains to evaluate and address risks of human trafficking and slavery: JM uses internal supplier audits and checklists to verify the qualifications of certain existing and potential future suppliers. Although these processes do not specifically focus on trafficking and slavery, if JM became aware of a circumstance involving this conduct in our supply chain, JM will conduct an investigation and take appropriate remedial action.
2. Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains: JM implements a risk-based internal audit program for suppliers in our direct supply chain. Although the audit program does not specifically focus on trafficking and slavery, if observed, this conduct would not be tolerated, and appropriate recourse taken.
3. Compliance certification: JM has purchasing agreements or purchase order terms and conditions in place with all our direct suppliers requiring them to comply with all applicable laws and regulations as a general rule of engagement. This compliance includes laws regarding forced labor and child labor. The company does not have a formal certification process.
4. Standards and procedures: Any supplier or employee found to be in noncompliance with either our terms and conditions or our policy against slavery and human trafficking, whether that violation was detected via self disclosure or through our audit process, will be reviewed for compliance action, which may result in termination of the relationship or employment.
5. Training: JM provides training on human trafficking and slavery (particularly with respect to mitigating risks within the supply chains of our products) to those company employees and management who have direct responsibility for supply chain management. Further, we require all JM salaried employees to complete our annual Code of Conduct training and certification and we have an internal process for enforcement of misconduct.