California Transparency in Supply Chains Act
Hunter Industries is committed to ensuring our supply chain reflects our values and we support the goals of the California Transparency in Supply Chains Act of 2010. The act requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains. We rely on a global supply chain to conduct business. It is important that our suppliers maintain high standards of quality and ethical business practices, and poor working and manufacturing conditions are unacceptable.
Hunter is developing a Supplier Code of Conduct, which will apply to all suppliers that produce goods, components or raw materials for Hunter Industries or any of its subsidiaries, divisions, or agents. This agreement will be implemented by mid-2016 and sets the basic requirements that all suppliers must meet in order to do business with Hunter Industries and provide the foundation for Hunter Industries’ ongoing evaluation of employment practices and environmental compliance of its suppliers. The agreement states suppliers shall not use involuntary labor of any kind, including forced labor, indentured labor, prison labor, or forced labor by governments, and shall no not subject workers to any form of compulsion, coercion or human trafficking. Suppliers shall employ only workers who meet the applicable minimum legal age requirements or are at least 15 years of age, whichever is greater. In the event that Hunter Industries becomes aware of any actions or conditions not in compliance with the Hunter Supplier Code of Conduct, Hunter Industries reserves the right to demand corrective measures. Hunter Industries reserves the right to terminate an agreement with any supplier who does not comply with the Hunter Supplier Code of Conduct.
Verification of product supply chains to evaluate and address risks of human trafficking and slavery.
Hunter Industries regularly performs geographic evaluations of its supply chain to evaluate the risk of noncompliance in slavery, human trafficking, and other human rights and labor issues. When choosing a new supplier of a certain size, this information is taken into consideration and a site visit is conducted to evaluate for any risks of human rights and labor issues. This analysis is not conducted by a third party.
Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.
Hunter Industries routinely audits our largest contract manufacturers and we have a goal by 2016 to audit our largest suppliers by dollars spent, once every three years. To date we have surveyed our largest suppliers on human rights and environmental issues. When on-site audits are required, they are conducted announced by Hunter personnel using a global questionnaire and performance is scored using a three-point scale of “action required, more information required, and acceptable”.
Certification by direct suppliers that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Hunter Industries is working with direct suppliers to certify that parts are free of “Conflict Minerals” as that term is used under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”). Currently there are no known minerals in our products from conflict regions, but the original source of raw material to some suppliers is not yet determined. When launched, our Supplier Code of Conduct will state that suppliers must comply with all relevant local laws and regulations including specific prohibitions against forced, prison or indentured labor and that suppliers may not subject workers to any form of compulsion, coercion or human trafficking.
Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
With regard to any issues identified in compliance audits of foreign manufacturers, a formal corrective action plan would be developed with specific timeframes in which to correct the problems. Hunter personnel will then visit these factories to confirm adherence to the corrective action requirements. While we will typically provide up to a year for suppliers to correct minor issues, we consider things such as forced/prison labor, slavery, human trafficking, child labor, physical/sexual abuse, and bribery or coercion to be zero-tolerance issues requiring immediate remediation or withdrawal of future purchase orders and Hunter Industries may terminate current production depending on the circumstances.
Training to company employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
Hunter Industries regularly conducts trainings for all employees who deal with our supply chain on the Foreign Corrupt Practices Act. We currently do not have training on mitigating risks of human trafficking and slavery within our supply chain.