1. CA Transperancy in Supply Chains Act
Training 2018 – McCain Foods USA, Inc.
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2. California Transparency In Supply Chains Act.
An estimated 21 million people are victims of forced labor.
11.4 million woman and girls, 9.5 million men and boys.
California is the world’s 7th largest economy
The California Transparency in Supply Chains Act is aimed at helping consumers make more informed purchasing choices.
Companies doing business in California are required to comply with the Act.

3. Web Site Notification
Act requires public disclosure via company website
Post “a conspicuous and easily understood link to the required information” on the business‘ home page.

4. Required Disclosures Verification Audits Certification
Internal Accountability
Training
Required Disclosures
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5. At a minimum, disclose to what extent, if any, the manufacturer engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by third parties.
Verification

6. At a minimum, disclose to what extent, if any, manufacturer conducts audits of its suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chain. The disclosure shall specify if the verification was not an independent, unannounced audit.
Audits

7. At a minimum, disclose to what extent, if any, that the manufacturer requires direct suppliers to certify that materials incorporated in the product comply with the laws regarding slavery and human trafficking of the country in which they are doing business.
Certification

8. Internal Accountability
At a minimum, disclose to what extent, if any, that the retail seller or manufacturer maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Internal Accountability

9. At a minimum, disclose to what extent, if any, that the manufacturer provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain.
Training

10. Act Requires disclosure – not action.
The Act applies even to companies that take no actions related to the five disclosure categories. A company could simply disclose that, as to each category, it does not take any action.
Act Requires disclosure – not action.

11. McCain Actions McCain Code of Conduct Supplier Code of Conduct
Contractually requiring Supplier to comply with all laws.
McCain Actions

12. McCain’s Code of Conduct specifically prohibits human trafficking and slavery in its work place and its product supply chains. Although McCain does not engage in third- party verification to evaluate and address risks, all complaints filed with the McCain Code of Conduct Hotline, hosted by a third party provider, are promptly and thoroughly investigated and handled as appropriate
McCain’s Dislosure

13. McCain requires its suppliers and contract manufacturers to adhere to the McCain Supplier Code of Conduct with respect to all aspects of business dealings. The McCain Supplier Code of Conduct, which suppliers are contractually required to follow, prohibits suppliers from engaging in or benefiting from any form of human trafficking. This includes the recruitment, transportation, transfer, harboring or receipt of persons, by means of threat or use of force or other forms of coercion, abduction, fraud, deception or abuse of power or a position of vulnerability.  Giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation is also strictly prohibited.  McCain’s suppliers are obligated to maintain necessary documentation to demonstrate their compliance with the Supplier Code of Conduct, and McCain reserves the right to audit their operations to ensure compliance. Currently, audits are not regularly performed, nor are they conducted by an independent party.

14. McCain’s Supplier Code of Conduct requires all direct suppliers that provide materials incorporated into the product to act in accordance with all applicable federal, state, and local laws and regulations, as well as international laws, when applicable.

15. All employees and contractors are expected to follow McCain’s Code of Conduct, which sets forth the requirement that specifically prohibits human trafficking and slavery and requires that all employees are treated fairly and in accordance with all federal, state and local laws. Any employees and/or contractors who are found to be in violation of McCain’s Code of Conduct are dealt with appropriately.

16. McCain provides annual training to all California- based company employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery and mitigating risks within supply chains.

17. Questions?