The purpose of the California Transparency in Supply Chains Act of 2010 (S.B. 657) is to provide the public with information about a company’s efforts to address the global issue of human trafficking and slavery. Printpack is opposed to human trafficking and slave labor at any level. We have taken the following steps to ensure that slave labor and human trafficking are not present in our direct supply chain:
Supplier Assessments and Verification
Printpack sourcing managers regularly interview suppliers about legal and other contractual compliance matters such as this and conduct periodic visits to suppliers’ facilities where inspections can be made first hand.
Printpack reserves the right to conduct audits, and has performed audits, of our direct raw materials suppliers. These audits are conducted by our internal audit and/or supply chain teams which are trained in assessing risks in our supply chain. Independent, unannounced audits and third party verifications are not used by us in the supply chain.
Printpack’s Supplier Code of Conduct prohibits suppliers from engaging in or supporting human trafficking or using or supporting slave labor in their supply chains. Annually, suppliers of direct inputs into Printpack’s products will be asked to certify in writing compliance with either Printpack’s Supplier Code of Conduct, or with the supplier’s own Code of Conduct which includes substantially similar requirements. Our standard Purchase Order Terms and Conditions also include these requirements, and we include similar provisions in our non-standard-form agreements with such suppliers when feasible. A supplier’s failure to comply with the requirements of our Supplier Code of Conduct or a certification request may result in termination of purchase orders, supply agreements and the supplier’s relationship with Printpack.
Internal Accountability and Training
We have prohibitions on slave labor and human trafficking in our Printpack Code of Business Conduct such that associates who become aware of such practices must report them in line with the reporting obligations contained in the Code. Failure to report violations can result in discipline up to and including termination. As with our Supplier Code of Conduct, our associates must also certify compliance with the Company Code annually in writing. Compliance training is given to all associates and additional information and instruction have been given to associates responsible for supply chain management and procurement.