California Transparency in Supply Chains Act of 2010 and U.K. Modern Slavery Act of 2015
T.D. Williamson, Inc. ("TDW") is committed to responsible sourcing and, specifically the elimination of human trafficking and slavery in our supply chain, if any.
Verification: TDW currently requests that its direct suppliers for TDW's tangible goods offered for sale ("Suppliers") complete an Onboarding Package as part of our initial intake process, and certify in all purchase orders that the Supplier acknowledges and agrees that "no applicable governmental laws, rules, or regulations have been violated in the manufacture or sale or shipment" of the items purchased in such purchase order. Our standard manufacturing agreement also requires Suppliers to represent that they have read and agree to act in a manner consistent with TDW’s Code of Business Conduct and Ethics which expressly states that "TDW 1) does not use or condone the use of slave labor or human trafficking; 2) denounces any degrading treatment of individuals or unsafe working conditions; and 3) supports [TDW's] products being free of conflict minerals."
TDW is currently in the process of updating our Onboarding Package to require current and prospective Suppliers to self-certify regarding the eradication of human trafficking and slavery.
TDW anticipates that its Supplier Standards and verifications will reserve the right for TDW to engage in its own verification process of Supplier representations or by engaging a third party to conduct such verifications.
Audits: TDW's standard manufacturing agreement currently reserves TDW's right to conduct onsite audits of its prospective and existing Suppliers manufacturing facilities . TDW conducts such audits of its top 20 Suppliers by sales volume through its own personnel on an announced basis.
TDW is in the process of revising its standard Purchase Order Terms & Conditions to expressly reserve the right to conduct onsite audits of its prospective and existing Suppliers to evaluate the Supplier's compliance with all applicable laws, regulations, rules, practices and procedures, as well as its Onboarding Package representations and anticipated Supplier verifications of TDW's Supplier Standards. TDW envisions that it may conduct such audits through its own personnel or an independent third party auditor, on an announced or unannounced basis.
Materials: TDW currently requests through its standard manufacturing agreement with Suppliers that its Suppliers undertake and agree to act consistently with the TDW Code of Business Conduct and Ethics, which states that "TDW … supports [TDW's] products being free of conflict minerals."
TDW is also in the process of requiring that Suppliers certify in the Onboarding Package and verifications to TDW’s Supplier Standards that materials incorporated into TDW's products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Accountability Standards: TDW's Code of Business Conduct and Ethics currently has a written policy setting out its accountability standards with respect to Forced Labor and Anti-Trafficking, and provides that any employee who violates the Code of Business Conduct and Ethics "will be subject to appropriate discipline, which may include dismissal."
Training: TDW has completed training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks within the supply chain.