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6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
7
No
{'index': '7', 'text': 'VISTA OUTDOOR INC.\u2028CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE\n\nAt Vista Outdoor we insist on ethical behavior, environmental stewardship and safety, and require that our suppliers do the same. To that end, our suppliers are prohibited from engaging in forced labor of any kind and are required to follow all laws related to worker wages, health, safety and conditions. Our Supplier Code of Conduct outlines and reinforces our commitment to ethical behavior at every level.\n\nWe regularly assess risk related to our supply chain based on geography, commodity purchased, quality and efficient performance. Depending on the supplier, the region and the nature of the commodity, we may conduct due diligence and/or announced internal or external audits on suppliers to assess compliance with Vista Outdoor standards and applicable laws. Vista Outdoor’s Supplier Code of Conduct and terms and conditions of purchase specifically prohibit human trafficking and slavery, and suppliers are required to warrant that all materials incorporated into our products are manufactured in compliance with the laws regarding human trafficking and slavery in the country or countries in which they are made. Suppliers failing to meet Vista Outdoor’s accountability standards are required to take corrective actions and are subject to termination. We are developing a training and documentation program for employees and management with direct responsibility for supply chain management on forced labor, including human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
VISTA OUTDOOR INC.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT DISCLOSURE Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': "Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010\n\nThe California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains.\n\nAlere supports the rights of all individuals to be free from slavery in the workplace. Alere abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. When entering into written contracts with its suppliers, Alere policy is to include in those contracts a requirement that they comply with laws applicable to the business being transacted, which include laws prohibiting slavery and human trafficking. By signing our contracts our suppliers certify that they conduct their business in compliance with all applicable laws, including but not limited to laws that prohibit slavery and human trafficking. A supplier's failure to honor its legal and contractual obligations to Alere would be a violation of law and a breach of contract. Alere endeavors to do business with reputable suppliers with proper business standards. Alere does not believe that additional verifications or independent audits are necessary to ensure that its suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
Company Disclosure Statement Pursuant to the California Transparency in Supply Chains Act of 2010 Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer provides training to employees on human trafficking and slavery? Broad policies such as ongoing dialogue on mitigating risks of human trafficking and slavery or increasing managers and purchasers knowledge about health, safety and labor practices qualify as training. Providing training to contractors who failed to comply with human trafficking laws counts as training. Answer yes or no. Answer:
supply_chain_disclosure_best_practice_training
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
4
No
{'index': '4', 'text': 'SUPPLY CHAIN TRANSPARENCY\n\nFor many years, 99 Cents Only Stores has had in place a policy against purchasing any merchandise manufactured as a result of human trafficking or slavery and, in fact, as a result of any coercive, abusive, or unlawful practice.\n\nIn 2004, 99 Cents Only Stores adopted the following policy, which has been on its intranet at all times since:\n\n“It is the Company’s policy not to purchase products known to be manufactured using exploitive or unfair labor practices. This means not purchasing products known to be manufactured by the use of: forced labor, abusive labor practices, child labor, or other practices that are illegal in the place at which the products being offered are manufactured.”\n\nGiven the largely closeout nature of much of the Company’s merchandise, its price points, and the ever-changing nature and composition of the merchandise it purchases and offers for sale, it is not feasible for the Company to comprehensively verify product supply chains or audit supplier compliance, but the Company does send its own employees to a number of the overseas factories from which it buys product for tours and announced inspections. Further, the Company also requires its direct suppliers to certify, in writing, that their products sold to the Company are not the result of any proscribed practices and that the supplier complies with the laws of all countries in which the supplier does business. In fact, the Company’s vendor contracts contain the following requirement:\n\n“It is Purchaser’s policy not to purchase products manufactured using exploitive or unfair labor practices, such as forced labor, abusive labor practices, or child labor. Neither will Purchaser buy merchandise made as a result of any practices that are illegal in the place at which the products being offered are manufactured. By signing or shipping under 99 Cents’ PO, Seller attests to the fact that after a diligent inquiry, Seller has ascertained that no product that is the subject of this Purchase Order has been manufactured using any such forced, involuntary, exploitive, or unfair labor practices.”\n\n\xa0Any supplier found to have falsely certified its compliance with the Company’s policy will no longer be used by the Company as one of its vendors. The Company’s buyers are also expected to comply with this policy, although it is not feasible for the Company to maintain a formal accountability program or to provide regular training on these topics to employees and managers operating in these areas, for the same reasons explained above.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
SUPPLY CHAIN TRANSPARENCY Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
0
Yes
{'index': '0', 'text': 'California Transparency in Supply Chains Act\n\n\xa0\n\nAbbott believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. Abbott is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. Abbott always has had and will continue to have a zero tolerance policy regarding human trafficking and slavery. Abbott has a global policy against trafficking and slavery in supply chains. Abbott engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Specifically, Abbott utilizes a supplier classification model to determine appropriate activity level to assess risk. A supplier may receive a letter, a survey or an on-site audit (usually announced ahead of time) based on this model. Information received from the supplier is then assessed to determine whether to take further steps. Currently, this verification is conducted by Abbott employees in its Global Purchasing Services Compliance department.\n\n\xa0\n\nAbbott’s Supplier Guidelines state our expectations to suppliers conducting business with Abbott that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. Abbott’s internal Code of Business Conduct also incorporates standards prohibiting slavery/trafficking or engaging in illegal behavior. Abbott requires direct suppliers to certify that materials incorporated into Abbott’s products comply with local and national laws of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Guidelines. Abbott maintains internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking. In particular, Abbott employees worldwide train annually on Abbott’s Code of Business Conduct. Likewise, all contractors assigned to Abbott are required to review and abide by Abbott’s Code of Business Conduct.\n\n\xa0\n\nEmployees and contractors assigned to Abbott who fail to abide by Abbott’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. Abbott provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
2
Yes
{'index': '2', 'text': 'In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. \n\nAcer is a member of the Electronic Industry Citizenship Coalition (EICC), an alliance of the world’s leading information and communications technology (ICT) companies. The EICC has published the Electronic Industry Code of Conduct (EICC Code) which establishes conduct standards for global ICT companies to improve working and environmental conditions. Acer actively works as part of the EICC to provide safeguards which prohibit supply chain use of slavery and human trafficking. \n\nAcer has adopted the EICC Code and requires adherence to this Code by its employees and direct suppliers. Acer also supports and participates in the EICC’s Freely Chosen Employment task force which is designed to help identify opportunities to share best practices among members, expand the code of conduct, and make recommendations on available tools and training. \n\nAcer has taken multiple actions to eradicate use of forced labor, slavery and human trafficking in its supply chain. These actions include: \n\nSupplier risk assessment \n\nAcer assesses the risk of inappropriate labor practices in its suppliers’ operations by evaluating several factors. These factors include supplier: assessment questionnaires, operational characteristics, business risk dynamics, results of prior audits and other relevant factors. Acer also considers the concerns of outside parties in making these risk assessments.\n\nSupplier audits \n\nAcer conducts announced on-site audits of its suppliers to ensure compliance with the EICC Code and takes seriously all forms of non-conformance. Audits are conducted by Acer employees and/or third-party consultants retained by Acer. Suppliers are selected for audit based on the results of the risk assessment analysis described above.\n\nAdditionally, Acer participates in the EICC Validated Audit Process (VAP), which employs an independent audit manager to inspect procedures and tools, and verify audit results. Acer employs varied auditing processes to ensure a robust audit program with complementary methods to validate and continually improve Acer’s supply chain adherence to the EICC Code.\n\nSupplier Declaration \n\nAcer requires all direct manufacturing suppliers to sign a Declaration of Compliance with the EICC Code. This Code obligates the suppliers to adhere to Acer’s standards of upholding the human rights of workers and treating them with dignity.\n\nSupply Chain Management Employee Training \n\nAcer has launched a training program for its employees with manufacturing supply chain responsibility. This training ensures that Acer employees in procurement roles are fully aware of the standards Acer has established for its suppliers to eradicate slavery and human trafficking in the Acer supply chain. The training also provides supply chain management employees with strategies to identify and respond to inappropriate supply chain labor practices. Acer’s supply chain personnel are also made fully aware of the responsibilities imposed on Acer’s suppliers via the EICC Code and the audit program Acer has instituted to ensure supplier compliance with this Code.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
In 2010 the California Transparency in Supply Chains Act of 2010 (SB 657) was passed and will go into effect on January 1, 2012. This law requires large retailers and manufacturers who do business in the state of California, and have annual gross worldwide sales of over $100 million U.S. dollars, to be transparent about the efforts they have undergone to eradicate slavery and human trafficking in their supply chain. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
1
Yes
{'index': '1', 'text': 'California Transparency in Supply Chains Act \n\nHuman trafficking and forced labor is a global issue that requires the combined efforts of countries and companies to raise awareness and combat all forms of trafficking. The United Nations defines it as an act of recruiting, transporting, transferring, harboring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them. Every country is affected by human trafficking, and men, women, and children can fall victim. Abercrombie & Fitch has taken proactive steps to mitigate the risk of human trafficking and forced labor in our supply chain. \n\nVerification \n\nIn order to verify that A&F\'s product supply chains do not use goods produced by forced or child labor, we regularly review updates to the U.S. Department of Labor\'s List of Products Produced by Forced or Indentured Child Labor so we can more closely monitor factories that may operate in the countries listed. Factories are also required to go through a rigorous approval process before they join our supply chain, including working with Sourcing, Sustainability, and Quality Assurance departments to make sure the factories meet company standards. \n\nAuditing \n\nTo ensure all the factories in our supply chain are fulfilling their obligation, Abercrombie & Fitch hires independent, third-party monitoring firms to audit them regularly. The auditors are experts in the local laws of the countries in which we produce, and they speak the local languages. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). We typically audit factories once per year, but we can visit more or less depending on the factory\'s performance and track record. To maintain the integrity of the audit, we do not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which we will audit the factory. \n\nFor the factories that need to be audited more frequently, such as certain High Risk factories, or when A&F is looking into using a new 3rd party monitoring firm, one or more associates from Abercrombie\'s Sustainability department will shadow the audit with the representatives from the monitoring firm to ensure A&F\'s Code of Conduct is followed. \n\nCertification \n\nAll business partners are contractually required to adhere to Abercrombie & Fitch\'s Code of Conduct, which states that "Abercrombie will not tolerate the use of convict, indentured, slave, bonded, or other forced involuntary labor, including human trafficking, either directly or indirectly, by its vendors, or by any subcontractors utilized by its vendors." When a vendor accepts a purchase order, they are confirming their compliance with our Code of Conduct and our zero-tolerance stance on human trafficking and forced labor. \n\nInternal Accountability \n\nWe have a zero-tolerance policy for involuntary labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory must take immediate steps to correct the problem. The factory is required to alert A&F on how they are correcting the issue and an A&F associate will work directly with the factory to ensure there are no recurrences. In addition, a full follow-up audit will be performed at the factory 6 months later to confirm the issue has been resolved. \n\nTraining and Awareness \n\nAll internal team members and managers directly involved in Supply Chain Management were required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks. We are happy to report that all participants passed the course, and found it to be very informative. \n\nAll of our major vendors were trained on human trafficking in mid-2011, during which they reviewed the clause in our Code of Conduct regarding involuntary (forced) labor and human trafficking. They also discussed how human trafficking is defined so that they understand the different acts, means, and purposes of human trafficking.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
3
Yes
{'index': '3', 'text': 'Corporate Responsibility and the Siemens Supply Chain*\n\nSupplier Code of Conduct\n\nSiemens wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions at the 177 countries in which we purchased goods and services in the last Fiscal Year (Oct 1st - Sept 30), this maxim of Siemens‘ business policy was considered in the principles of the “Code of Conduct for Siemens Suppliers”. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens “Business Conduct Guidelines”, which establishes fundamental principles of sustainability and apply to the entire company.\n\nSiemens operates not only in accordance with clear Business Conduct Guidelines, which are mandatory worldwide, but also with directives to concentrate business with only the best suppliers who agree to and comply with our standards in the supply chain. In the long term we cooperate only with suppliers who place as much value on Sustainability as we do and who adhere to the principles of Global Compact with respect to human rights and work relationships.\n\nIn order to continuously monitor and improve the performance of our suppliers we utilize a consistent Supplier Management System. At the foundation of this system is our process by which we obtain supplier contractual commitment to responsibilities towards their stakeholders and the environment through the Siemens Supplier Code of Conduct. The code addresses the following concepts:\n\n\t\tCompliance with laws. \n\n\t\tProhibition of Corruption and Bribery \n\n\t\tRespect for Basic Human Rights of Employees (which includes to refuse to employ or make \u2028anyone work against his or her will) \n\n\t\tProhibition of Child Labor \n\n\t\tHealth and Safety of Employees \n\n\t\tEnvironmental Protection \n\n\t\tPromotion of the above principles in the supply chain of the supplier \u2028The full Supplier Code of Conduct document and detailed description of the key provisions can be found under the following link: https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx) \u2028Once a supplier becomes part of the Siemens supply chain, it then becomes subject to the compliance verification activities established as part of the Supplier Management System. The system uses a combination of four approaches to accomplish the compliance verification process. These approaches are: Sustainability Self Assessments, Risk Evaluations performed by the responsible Siemens Buyer, Sustainability Audits performed by third parties and Siemens Quality audits. These audits include determining if the supplier adheres to the Code of Conduct. Further information on our systematic approach can be found at www.siemens.com/sr/detection-modules \u2028Siemens Management System considers the assessment and audit findings and then employs supplier development actions which establish improvement measures to be taken by suppliers to mitigate or correct issues raised in audit findings. If a supplier fails to execute the agreed upon measures, Siemens may terminate any existing business with the supplier. This termination right is established in Siemens supplier contracts and purchase terms and conditions. \n\n \n\nThe number of 3rd party audits and number of findings are published in the Siemens Sustainability Report, and can be accessed through the following links: (www.siemens.com/scm/sustainability; or specific suppliers chapter under : http://www.siemens.com/sustainability/pool/en/current-reporting/sr2010_suppliers.pdf).\n\nEnergy Efficiency Program for Suppliers\n\nIn order to orient our entire supply chain in an ecological manner, we work closely with our suppliers to identify and implement measures for the efficient use of resources and the reduction of greenhouse gas emissions. To this end, we developed our Energy Efficiency Program for Suppliers (EEP4Suppliers) which provides access to know-how and experience from our own Environmental Program and Environmental Portfolio.\n\nIn fiscal 2010, we successfully piloted EEP4Suppliers at 17 production facilities operated by major suppliers. Plans call for the first 1,000 suppliers to be integrated in the EEP4Suppliers program by the end of fiscal 2012.\n\nOrganization Awareness.\n\nAll Procurement professionals within the Siemens Supply Chain organization are trained on the “One Supplier Certification” process and related Code of Conduct requirements so that the principles can be effectively explained to suppliers. Additionally Siemens conducts sustainability workshops with our suppliers in higher-risk-countries. The workshops include presentations by Environment, Health and Safety Officers who lead break-out sessions that address human right topics such as worker safety.\n\nWeb Based Trainings in Sustainability are available for suppliers as well as internal Siemens personnel and can be accessed through the following link. https://w9.siemens.com/cms/supply-chain- management/en/sustainability/expectations/principles/Pages/code-of-conduct.aspx\n\n* This information explains Siemens activities in support of and commitment to the principles found in the California Transparency in Supply Chains Act of 2010, to eradicate human trafficking and slavery from supply chains.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
Corporate Responsibility and the Siemens Supply Chain* Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
7
No
{'index': '7', 'text': "California Supply Chain Act \n\nAir Products is opposed to slavery, human trafficking and the use of forced labor of any kind. Air Products maintains and enforces a\xa0Human Rights policy\xa0which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor.\xa0 The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy and to report suspected violations of the policy through a variety of available reporting channels, and ensures employees that retaliation will not be tolerated.\xa0 Air Products’ managers are trained in the proper enforcement of all Company policies, including but not limited to the Human Rights policy.\n\nIn furtherance of its commitment to Human Rights and its opposition to the use of forced labor of any kind, Air Products routinely requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all\xa0 laws, rules and regulations relating to slavery and human trafficking.\xa0 Air Products’ managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts.\xa0 Air Products may also require its suppliers, vendors and contractors to agree to abide by the Company’s Human Rights policy, or demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy.\xa0 Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.\xa0 Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance.\xa0 Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances.\xa0 Audits are generally conducted upon 30 days advance notice.\n\nQuestions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien."}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Supply Chain Act Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
6
No
{'index': '6', 'text': 'The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers.\n\nAgilent’s efforts to eradicate slavery and human trafficking in its supply chain include the following:\n\n\t\tWritten Policies and Procedures: Agilent maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Agilent’s Supplier Code of Conduct. Among other provisions, the Supplier Code of Conduct requires all Agilent suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.” The Supplier Code of Conduct also requires Agilent suppliers to abide by the bans on forced or compulsory labor set forth in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization. \n\n\t\tSupplier Certifications: Agilent requires all suppliers to certify their compliance with our Supplier Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking. \n\n\t\tThird-Party Audits: Agilent has the right to audit all suppliers for compliance with the Agilent Supplier Code of Conduct. Agilent employs an independent third party to audit and evaluate our suppliers’ compliance with our Supplier Code of Conduct, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010. \n\n\t\tAccountability Standards: Agilent has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. Agilent’s disciplinary policy permits the termination of a supplier for even a single violation and likewise permits a range of measures, up to and including termination, for Agilent employees involved in any similar misconduct. \n\n\t\tEmployee Training: Agilent conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring that Agilent’s suppliers abide by the Agilent Supplier Code of Conduct, including its prohibitions on slavery and human trafficking. \u2028It is essential to Agilent that all persons involved in the production of our products, whether Agilent employees or not, are treated with dignity and respect. Agilent will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain. \n\nDocument Number: Stellent ID 037662 November 2, 2011'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
The California Transparency in Supply Chains Act of 2010 (SB 657) goes into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Agilent is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification
5
No
{'index': '5', 'text': 'California Transparency in Supply Chains Act of 2010 - Corporate Disclosure\n\nPolicy on Slavery and Human Trafficking\n\nAethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:\n\nEngaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;\n\nEngaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nProcuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;\n\nUsing forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.\n\nAny Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency. \n\nAll Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government. \n\nAethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.'}
{{text}} Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
California Transparency in Supply Chains Act of 2010 - Corporate Disclosure Question: Does the above disclosure meet the following criteria: Does the above statement disclose whether the retail seller or manufacturer engages in verification and auditing as one practice, expresses that it may conduct an audit, or expressess that it is assessing supplier risks through a review of the US Dept. of Labor's List? Answer yes or no. Answer:
supply_chain_disclosure_best_practice_verification