California's New Anti-Human Trafficking Law

California’s Transparency in Supply Chains Act (SB657) went into effect on January 1st, 2012. Retailers and Manufacturers with over $100 million in revenues will now have to disclose on their websites what they are doing to prevent slavery and trafficking in their supply chains all the way down to the dirt.

Companies will have to report if they are doing the following:

–      Engage in verification of product supply chains to evaluate and address risk of trafficking and slavery;

–      Conduct audits of suppliers for compliance with company standards regarding trafficking and slavery;

–      Require Direct Suppliers to certify that material incorporated into the product complies with laws regarding slavery and human trafficking where supplier does business;

–      Maintain internal accountability standards and procedures for those failing to meet the company’s standards;

–      Provide training on human trafficking and slavery, particularly with respect to mitigation risk within the supply chain of products.

Investors issued a guidance document for implementing the California law and going beyond to embrace an entire human rights framework.