Ethical Sourcing

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Slavery and Human Trafficking — How to Build Your Compliance Program

The California Transparency in Supply Chains Act of 2012 (“California Act”) applies to retailers and manufacturers with annual worldwide gross receipts over $100 million that are doing business in California. Those entities are required to disclose (by statements posted on their websites) their efforts to eradicate slavery and human trafficking from their direct supply chains … Continue Reading

Conflict Minerals — For European Companies That Haven’t Started The Process, Here’s How To Build Your Compliance Program

When the US Securities and Exchange Commission’s conflict minerals rule was issued in 2012, US reporting companies (and their suppliers) developed and implemented conflict minerals compliance programs. Companies have continued to enhance and beef up their programs since then. Now, companies should be supplementing their compliance programs to be ready to address the requirements of … Continue Reading

Here We Go Again — New Proposed Resource Extraction Payment Rules

As we discussed in posts on September 3, 2015 and on October 2, 2015, Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the SEC to issue resource extraction payment rules.  The purpose of those rules was to promote the federal government’s desire for transparency about resource extraction payments made by commercial entities to governments around the world.   The initial … Continue Reading

Move UK Slavery and Human Trafficking Compliance to the Top of Your To-Do List

On October 29, 2015, the UK Government issued Guidance on the requirements of the Modern Slavery Act.  The UK Modern Slavery Act requires many commercial organizations doing business in the UK to post a slavery and human trafficking statement on their homepages.  It is now clear that those businesses (especially those with year-ends on or after March 31, 2016) need to turn their … Continue Reading

Supply Chain Policy and Disclosure Leads to Human Trafficking/Slave Labor Litigation

There has been a lot of discussion about the case against Costco relating to its California Transparency in Supply Chains Act disclosure.  Here is the link to the post about the Costco case that I co-wrote for our Global Supply Chain Law Blog .  This case is an example of how supply chain policy and disclosure can lead to litigation.   … Continue Reading
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