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California Transparency in Supply Chains Act of 2010

California Transparency in Supply Chains Act of 2010

At Capablanca, we are committed to the protection and advancement of human rights.  We believe in partnering with others who share our values and understand the importance of responsible business practices. As a company affected by the California Transparency in Supply Chains Act of 2010 (SB657), we are providing the following information about our efforts to evaluate and address any risks of human trafficking and slavery in our direct supply chain.

Verification. We have various internal means by which we assess and evaluate the risks of human trafficking and slavery in our supply chains including (i) reviewing supplier profile information, (ii) conducting internal quality assessments, and/or (iii) engaging independent third parties to conduct risk assessments through inspections and site visits.

Audits. To ensure that our suppliers comply with all applicable laws within their countries of operation and with company standards, we require suppliers to allow us and/or our agents to engage in certain monitoring activities. These monitoring activities may include, but are not limited to, unannounced and announced site inspections, reviews of books and records, and interviews with employees.

Certification. As a condition of doing business with us, suppliers must comply with our supplier code of conduct and certify that they will comply with all applicable laws governing employment, wages, working conditions, benefits, and safety, in addition to all applicable environmental laws and regulations. Furthermore, our commercial agreements with suppliers include provisions specifically prohibiting practices associated with human trafficking and slavery.

Accountability. All our employees are expected to abide by our conduct policy, which requires employees to act ethically and comply with all applicable laws. Any failure to comply with our conduct policy could lead to disciplinary action, up to and including termination. In the case of non-compliance with company standards regarding human trafficking and slavery, we reserve the right to terminate our business relationship with any non-complying supplier or contractor.

Training. Although we do not currently conduct formal training for our employees with responsibility for supply chain management, all such employees have significant experience in their positions and have conducted numerous inspections and site visits. All such employees are aware of issues concerning human trafficking and slavery and are required to comply with company standards and all applicable laws.