The California Transparency in Supply Chains Act

VERIFICATION:

O’Sullivan Films is thoroughly committed to fair labor practices including, but not limited to, the elimination of any form of slavery or human trafficking within our supply chain.  All raw materials are purchased in compliance with the Uniform Commercial Code of the United States.  Very specific purchase contract language is also employed to insure that all labor utilized to produce raw materials in our supply chain complies with all EQUAL EMPLOYMENT OPPORTUNITY PROVISIONS as shown below: 

EEOP:

THESE TERMS AND CONDITIONS INCORPORATE THE EQUAL EMPLOYMENT OPPORTUNITY PROVISIONS OF 41 C.F.R. 60-­‐250, AS AMENDED AND ALL PROVISIONS OF 41 C.F.R. 60-­‐741, AS AMENDED.  SELLER CERTIFIES THAT IT IS IN COMPLIANCE WITH THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT AND ALL FURTHER PROVISIONS OF C.F.R. 60-­‐1, AND EXECUTIVE ORDERS 11246, AS AMENDED BY EXECUTIVE ORDER 11375.

AUDITS:

O’Sullivan Films conducts quality audits on select suppliers on a consistent planned annual basis.  Effective July 1, 2015, all quality audits will also have a category to evaluate supplier compliance with fair labor practices and standards.   

CERTIFICATIONS:

O’Sullivan Films does not require supplier certifications at this time pertaining to laws regarding slavery and human trafficking.  However, when purchase contracts are awarded to suppliers, their acceptance of our Purchase Order does also constitute acceptance of the EQUAL EMPLOYMENT OPPORTUNITY language incorporated within the purchase contract.  

INTERNAL ACCOUNTABILITY:

O’Sullivan Films does have internal accountability standards and procedures as prescribed in our sourcing contract

(Purchase Order) language for suppliers to comply with EQUAL EMPLOYMENT OPPORTUNITIES.  (SEE VERIFICATION SECTION ABOVE FOR THE SPECIFIC LANGUAGE).

TRAINING:

O’Sullivan Films employees that have direct responsibility for supply chain management very aware of CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT.  The specific training has been done via Internet research and formal notifications as prescribed by STATE OF CALIFORNIA DEPARTMENT OF JUSTICE.