California Transparency in Supply Chain Act Disclosure
The California Transparency in Supply Chains Act of 2010 requires certain companies doing business in the State of California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale.
Orchard is taking the following actions to eradicate slavery and human trafficking from our supply chain:
Orchard is in the process of requiring that every vendor that sells products and/or services to Orchard is required to comply with its Vendor Code of Conduct that outlines all the requirements for doing business with Orchard. Specifically, the Vendor Code of Conduct states the following:
Forced Labor: Vendors shall not use any form of forced, bonded, indentured, trafficked, slave or prison labor, with the exception of government approved programs that utilize convicts or prisoners on parole, supervised release or on probation or in any penal or reformatory institution. All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. All workers must not be required to surrender any government-issued identification, passports or work permits as a condition of employment.
Child Labor: Child labor is strictly prohibited. The minimum age for employment shall be the higher of 16 years of age, the minimum age for employment in that country or the minimum age for completing compulsory education in the country of manufacture
Employment Practices: Vendors must have hiring practices that verify accurately age and ability to work legally.
Compliance with Laws and Orchard’s Policies: Vendors must fully comply with all applicable national and/or local laws and regulations and Orchard’s policies. To the extent that Orchard’s policies impose a higher standard than what is required by applicable national and/or local laws and regulations on its Vendors, such higher standard will prevail.
The Vendor Code of Conduct requires that all vendors maintain all documents to demonstrate compliance and provide such documents to Orchard, whenever requested.
Verification, Auditing, Accountability and Training
Orchard currently is identifying how to verify product supply chains to evaluate and address risks of human trafficking and slavery, to conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, to develop internal accountability standards for vendors failing to meet company standards regarding slavery and trafficking and to train employees and management, who have direct responsibility for supply chain management, on human trafficking and slavery.
In connection with Orchard’s employees, Orchard requires all of its employees to comply with the Code of Business Conduct and Ethics which covers areas that include compliance with laws and employee relations. Failure of any Orchard employee to comply with the Code of Business Conduct and Ethics may result in disciplinary action in addition to civil and criminal penalties.