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We help companies throughout the product supply chain create sustainable businesses.
Our consulting services include creating enterprise-level sustainability visions, goals and strategies; re-engineering internal processes to reflect sustainable best practices; maximizing the sustainability of today's complex supply chains and assisting with communicating sustainability information in writing and in media.
Our training services include webinars and in-person seminars for large to small groups on topics ranging from GHG accounting to Mastering Supply Chain Sustainability and Social Responsibility. We can custom design training to suit your needs.
We work in a variety of industries. We are extremely sensitive to clients' budgets and their capacity for change.
Whether it's an environmental or social responsibility issue, our team of professionals is ready to help your business. Please contact us to learn how we can help you.
Call 212-343-1006 today.
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Greetings!
With 2013 well under way (and racing fast ahead, it seems!), we hope that you're making advances with your sustainability challenges and opportunities. This month, our Feature Article covers the California Transparency in Supply Chains Act ... a disclosure law aimed at requiring companies to reveal what they are doing to address human trafficking and slavery in their supply chains.
In our Ideas You Can Use Now section, we provide some ideas about how to comply with the California law and create the type of social responsibility framework in your supply chain that can mitigate problems in human rights.
Finally, in the Calendar section, we suggest some sustainability-related events in the coming month or two that you might want to investigate.
Happy reading!
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 Feature Article: California's Transparency in Supply Chains Act |
Way back in 2010, California passed a law aimed at improving the transparency stakeholders can get into human trafficking and slavery activity associated with corporate supply chains. Although the law went into effect in January 2012, many companies are still getting tripped up by not complying. While there is no financial or criminal penalty under the law, it doesn't make sense to ignore this important development.
Under the Act, if your company's annual revenue exceeds US$100 million and you do business in California, you must disclose (usually on your company's website) the following information about how you deal with these two human rights issues:
1. How your company verifies human trafficking and slavery risks in its supply chain. For example, do you engage outside experts to do a risk analysis and provide you with recommendations?
2. The extent to which you audit suppliers for their compliance with your corporate human trafficking and anti-slavery policies. You'll want to say whether you use outside auditors and whether the audits were unannounced.
3. Whether you require your Tier 1 suppliers to certify in writing that they are in compliance with all local laws regarding human trafficking and slavery. The law says "wherever they operate," so some suppliers might be confused or even push back, honestly.
4. What internal accountability processes you have in place to address non-compliance situations. For example, do you have a "whistleblower policy" that encourages and facilitates reporting possible abuses?
5. How you train your supply chain management team in human trafficking and slavery issues. For example, do you conduct annual training programs on human rights issues that cover human trafficking and slavery? So the question is - have you gathered this information about your company and worked with your communications department to craft a concise, meaningful and honest disclosure statement? And if you currently don't do what the law is asking, then you should begin work internally (ideally, with the assistance of outside experts) to put in place the policies, procedures and training covering both your supply chain and internal team that can effectively work to prevent human trafficking and slavery abuses, which are more insidious and prevalent in today's global supply chains than you might believe. We've written an Information Brief on the California law. Contact us for your copy or download it from our website, www.kuhnassociatesllc.com.
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Ideas You Can Use Now!
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Here are some ideas about how best to deal with the California Transparency in Supply Chains Act: - check your company's website to see whether the required disclosure appears anywhere (a link to the complete text must appear on the homepage)
- if there's no disclosure, then assemble a team of responsible personnel (supply chain management, communications and legal personnel come to mind) to run through a checklist of the law's requirements
- draft a compliant disclosure statement and put it on your website now, even if you don't have every single best-practice element of a human trafficking and anti-slavery program in place
- the California law fairly well reflects best practices in these areas, so if you are missing one or more elements then begin work internally or with outside experts (the Fair Labor Association (www.fairlabor.org) has some free resources) to build a program appropriate to your circumstances.
If you have questions or comments on what we have presented here or want help complying with the California law, then please contact us by telephone at 212-343-1006 or email us at info@kuhnassociatesllc.com.
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Calendar of Events
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Here are a few of the many interesting sustainability events happening in the coming months: April 7 - 10, Chicago, IL - The 8th Annual Sustainable Meetings Conference, sponsored by the Green Meetings Industry Council, takes over part of McCormick Place to explore and share ideas about holding environmentally-friendly meetings and events. Visit http://www.gmicglobal.org/?page=annualconference for more information. April 15 - 16, Bethesda, MD - T he 2013 Smart and Sustainable Campuses Conference taps into the innovative culture of education to address sustainability-related issues in its own industry. You can register at http://www.sustainability.umd.edu/content/community/SSCC.php. May 1 - 2, San Francisco, CA - CERES Conference 2013. Connect with sustainability leaders from around the world to discuss how to tackle sustainability issues on a global scale. Visit www.ceres.org.May 22 - 24, Amsterdam, The Netherlands - The Global Reporting Initiative Conference on Sustainability and Reporting focuses on ways to convey sustainability-related information with integrity, honesty and in a manner consistent with best practices and your peers. Visit https://www.globalreporting.org/information/events/conference2013/Pages/default.aspx. |
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Thanks for reading! Please contact us today to discuss anything you've read here, suggest a topic for a future Newsletter edition or learn how we can help you build a more sustainable business.
Call 212-343-1006 or email us at
Sincerely, |
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