CORPORATE DISCLOSURE IN COMPLIANCE WITH SB657 CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT JANUARY 2012
Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufactures doing business in California to disclose their efforts to eradicate slavery and human trafficking in their own direct supply chain.
Ethical Commitment/Internal Accountability
Wahl Clipper is committed to conducting its business in a lawful and ethical manner and expects its employees and suppliers to conduct themselves in the same manner. In that spirit, Wahl Clipper is committed to compliance with the California Transparency in Supply Chains Act. All of Wahl Clipper’s employees and suppliers must adhere to our Workplace Standards, which require compliance with all laws, including laws addressing slavery and human trafficking.
Compliance within Wahl Clipper Supply Chain
Wahl Clipper is in the process of requiring all of its direct suppliers to certify that goods and materials used by them in their products they provide to Wahl Clipper comply with Wahl Clipper’s standards with respect to slavery and human trafficking. In its efforts to confirm compliance with the specific provisions of Wahl Clipper Corporation Workplace Standards and to confirm and document compliance with the Act, the Company declares the following:
- The Company is in the process of verifying its product supply chains to evaluate and address the risks of human trafficking and slavery using internal resources, or where appropriate or feasible, independent third parties.
- The Company reserves the right to audit its suppliers to evaluate their compliance with Company policies and procedures including at times, where appropriate or feasible, through unannounced independent third party visits, and will exercise this right in appropriate circumstances.
- The Company maintains Workplace Standards to which it requires its suppliers to adhere. The Company requires its direct suppliers to certify that their products are made in compliance with the laws regarding human trafficking and slavery of the countries in which the suppliers are doing business.
- The Company is putting in place internal accountability standards and procedures for suppliers failing to meet company standards regarding human trafficking and slavery.
- The Company is in the process of providing training on human trafficking and slavery to Company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chain of products.
Wahl Conflict Mineral Sourcing Policy
Minerals originating from Democratic Republic of Congo (DRC) are sometimes mined and sold in violation of human rights. Also it is believed these minerals are sometimes mined and sold under the control of armed groups to finance conflicts of violence. Some of these minerals can make their way into the supply chains of products used around the world including those in our industry. Wahl Clipper Corporation’s suppliers acquire and use minerals from multiple sources worldwide. We are committed to corporate responsibility and respecting human rights in our own operations and in our global supply chain. It is our goal to not use conflict minerals, defined as, tantalum, tin, tungsten, and gold in our products that would directly or indirectly finance or benefit the identified groups in the DRC or adjoining countries while continuing to support responsible mineral sourcing in the region. Wahl Clipper Corporation expects our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure the products and components supplied to us containing conflict minerals are DRC conflict free. Wahl expects our suppliers to comply with our Workplace Standards and perform their business in alignment with Wahl Clipper Corporation’s supply chain responsibility expectations. In support of this policy, Wahl Clipper Corporation will:
- Exercise due diligence with relevant suppliers consistent with the Conflict Free Sourcing Initiative www.conflictfreesourcinginitiative.org and encourage our suppliers to do likewise with their suppliers.
- Provide and expect our suppliers to cooperate in providing due diligence information to confirm that tantalum, tin, tungsten, and gold in our supply chain are conflict free.
- Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
Any supplier that does not comply with the Wahl Corporation Workplace Standards will be required to provide Wahl Clipper with an action plan to achieve compliance within a reasonable period of time. Suppliers who fail to comply with Wahl Corporation Workplace Standards within a reasonable period of time will jeopardize its relationship with Wahl Clipper and could lead to termination.