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California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010​ (SB 657) seeks to eliminate slavery and human trafficking from product supply chains. Effective January 1, 2012, SB 657 requires companies doing business in California to disclose their efforts to make sure that their supply chains are free from practices that could be construed as slavery and human trafficking. 

The Company has zero-tolerance for both forced labor and child labor.  We expect our suppliers to recognize and obey laws that require them to treat their workers fairly, with dignity and respect, and to provide a healthy and safe work environment.

Risk-based Supplier Assessments

The Company uses several tools in our assessment of where there may be risk of forced or compulsory labor. We require all suppliers to complete a self-assessment in which suppliers must indicate whether they have policies consistent with the Company’s Supplier Code of Conduct, whether they train their employees in these principles and whether these principles are cascaded to their suppliers. These results are reflected on supplier performance scorecards.
We are currently evaluating the usage of targeted audits based on the evaluations of supplier self-assessments and other risk indicator criteria.


​All new purchase orders since late 2009 contain language specifically forbidding the use of forced, child or compulsory labor. This will gradually encompass all Company purchase orders. Contracts state that Company may request suppliers to certify in writing its compliance (and that of its subcontractors) that there are not utilizing slave, prisoner, child, or any other form of forced or involuntary labor in connection with the supply of goods or provision of service.
While we do not currently require explicit certification of suppliers that the materials they provide comply with local laws regarding slavery and human trafficking, this is being evaluated as part of our review of Purchasing Terms and Conditions.

Training & Capability Building Programs

To help Procurement and Supplier Quality personnel to recognize their role in ensuring responsible working conditions, Company requires them to participate in training on the issues surrounding global working conditions, as well as how to identify potential risk scenarios that could indicate problems.
The Company partners with NGO’s (Non-Governmental Organizations) and multi-stakeholder groups to develop and maintain processes and tools to identify potential risk and to help in the reduction of human rights violations in the supply chain.
Partnering with other automakers and AIAG (the Automotive Industry Action Group), we also provide mandatory training to suppliers in high-risk areas at no cost. Suppliers who attend the training are required to cascade the training materials and messaging to their suppliers, delivering these expectations to a broader audience than we could do directly. The training covers multiple aspects of human rights infringements, focusing primarily on forced, compulsory and child labor.
Additional training and tools are in development for 2012 and will be available at no cost to suppliers through our Supplier Portal, the required communication channel for all Company suppliers. In addition, anyone who has identified potential problems can contact our Sustainability Group at


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