Carl Buddig's Disclosure In Compliance With The California Transparency In Supply Chains Act

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (the "Act") requires certain retailers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their direct product supply chains. Carl Buddig strongly believes in the importance of human rights standards and prohibits any type of slavery or human trafficking in its own supply chains and expects its suppliers to also comply with the requirements of the Act. To ensure compliance with the Act, Carl Buddig has implemented the following actions:

Verification/Certification:
Carl Buddig requires all its suppliers to adhere to laws addressing slavery and human trafficking. To ensure compliance, Carl Buddig has implemented a Supplier Code of Conduct which sets forth specific ethical and legal standards as well as requirements that Carl Buddig expects its suppliers to meet when conducting business. Verification of suppliers' adherence to Carl Buddig's standards is done internally through the suppliers' acknowledgment of their understanding and agreement to abide by the Supplier Code of Conduct. Carl Buddig has sent letters to all of its suppliers advising of the implementation of the Act, and requested all of its suppliers to certify that the materials incorporated in the products supplied or distributed to Carl Buddig comply with existing local and federal laws regarding slavery and human trafficking in the country(ies) in which they operate and conduct business.

Auditing:
In addition to maintaining a Supplier Code of Conduct, Carl Buddig will conduct annual risk-assessments of all its current and potential suppliers to determine the level of risk associated with the suppliers' compliance with the Code of Conduct. Carl Buddig may also visit the facilities of any high-risk suppliers and/or conduct audits (directly or through a third party) of the suppliers' employment records and practices. In most cases, audits will be announced.
Carl Buddig will also promptly investigate any reports alleging human trafficking and slavery in the supply chain. If Carl Buddig believes that a supplier's conduct is not in compliance with the Code of Conduct and/or any applicable laws addressing slavery or human trafficking, the supplier will be allowed a cure period to remedy any non-compliance. A supplier's continued engagement in improper conduct may result in termination of the business relationship.

Internal Accountability/Training:
By the end of 2012, Carl Buddig plans to train all of its employees and supervisors on human trafficking and slavery issues, including instructing them to recognize and properly respond to or advise the appropriate company official of any potential issues in their supply chain. Employees' and/or supervisors' failure to abide by Carl Buddig's practices regarding human trafficking and slavery matters will result in disciplinary action, up to and including termination.


Carl Buddig's Supplier Code of Conduct

Carl Buddig is committed to running and operating its business by adhering to the highest ethical standards and by complying with all applicable laws and regulations in the country(ies) in which it operates. Carl Buddig expects its suppliers to work diligently and conduct their business by abiding by the same ethical and legal standards. While this Code of Conduct provides suppliers an overview of Carl Buddig's principles and ethical standards, as well as expectations with respect to key areas of corporate responsibility, it is not intended to be exclusive, and suppliers must take reasonable measures to ensure that they conduct their business in full compliance with applicable laws, rules, and regulations in the country of operation.

Labor and Human Rights:
Suppliers must uphold the human rights of their employees, and implement in their business practice procedures and controls that:

  • Prohibit child labor consistent with the minimum age provisions of applicable laws and regulations.
  • Prohibit discrimination, physical or verbal harassment, and forced or compulsory labor.
  • Respect the right of the employees to freely associate, organize and bargain collectively in accordance with all the applicable laws.
  • Ensure compliance with all applicable wage and hour laws, including as they govern the number of maximum work hours, overtime, vacation time, leave periods, holidays, and any other legally mandated benefits.
  • Verify the employment eligibility of their employees by reviewing relevant documentation, and only employ workers with a legal right to work.

Product Safety and Quality:
Carl Buddig is committed to delivering quality and safe food products. Carl Buddig expects its suppliers to similarly consider the safety and quality of products to be of utmost importance and to comply with government and food safety requirements and specifications at all times.

Environment, Health and Safety:
Suppliers must be committed to maintaining safe working conditions and a healthy work environment for their employees, as well as conducting their business in an environmentally responsible manner. Suppliers must therefore:

  • Comply with all relevant local and national laws, codes, regulation and standards.
  • Include appropriate controls, safety procedures, preventive maintenance and proper protective equipment in compliance with the applicable laws and regulations.
  • Establish procedures to manage and report occupational injuries and illnesses in accordance with applicable laws.
  • Maintain compliance with the environmental laws and regulations, and conduct business responsibly to preserve the environment and reduce the impact of their operations on the environment.

Animal Wellbeing:
All suppliers must implement humane procedures to prevent the mistreatment of animals.

Ethics:
Carl Buddig holds its suppliers to the highest standards of ethics and prohibits any form of corruption, bribery, extortion, and embezzlement. Suppliers must also abide by fair business standards and practices as they relate to advertising, sales and competition.

Compliance and Supplier Responsibility:
Suppliers must establish and maintain a monitoring and record keeping system to ensure compliance with this Code of Conduct as well as all applicable laws and regulations. Carl Buddig reserves the right to verify its suppliers' compliance with its requirements, including visiting its suppliers' facilities and/or auditing (directly or through a third party) supplier employment records and/or practices.