GENERAL CABLE’S INFORMATION REGARDING CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010
As a global leader in our industry, we fully recognize our responsibility to operate within the spirit and letter of the law and to maintain high ethical standards wherever we conduct business. General Cable does not condone or tolerate efforts or activities to achieve results through illegal or unethical dealings anywhere in the world.
General Cable’s suppliers know that General Cable is concerned not only with results, but also with how those results are achieved. We expect all of our suppliers to conduct their businesses with the same high standards. We will actively seek business relationships with suppliers who share our values and promote the application of these high standards among those with whom they do business.
The State of California Transparency in Supply Chains Act of 2010 (the “Act”) requires that manufacturers and retailers disclose their efforts to eradicate slavery and human trafficking from the supply chain. The steps below describe General Cable’s efforts to comply with the Act (the numbered bolded topics are directly from the Act):
1. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
The General Cable Code of Ethics and Business Conduct specifically states that “[w]e do not employ children (or anyone under the age of 14) and follow all applicable laws regarding these standards. We expect our suppliers and other business partners to comply with applicable labor and human rights laws. Our Company does not use forced, indentured or involuntary labor, and we do not tolerate human trafficking from any of our suppliers or business partners.” General Cable encourages its employees and business partners to report any violation of its Code of Ethics and Business Conduct through its Ethics Helpline, which is a 24-hour phone line and website maintained by our Global Compliance Team and administered by an independent third-party provider. General Cable is currently developing a protocol to evaluate and identify high-risk suppliers on a number of parameters, including known risks and country location. Depending on the ultimate framework of such evaluation process, one or more third party verification entities may be used. General Cable is also considering use of the U.S. Department of Labor’s Bureau of International Labor Affairs (“ILAB”) “List of Goods and Countries” as an aid in such evaluations.
2. Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
Through pertinent supplier requirements, General Cable affords itself the ability to conduct audits to ensure compliance with company policies and regulations, including its Code of Ethics and Business Conduct. Depending on the circumstances surrounding any such audit pursued, such audit may be unannounced and/or conducted by a third party. Other desired audits may be conducted upon notice to the supplier and/or by General Cable personnel. Pursuant to General Cable’s Code of Ethics and Business Conduct, failing to fully cooperate with an audit or investigation is a violation of our Code and may result in disciplinary action including termination.
3. Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
As a standard, General Cable seeks to include in its purchasing contracts language mandating that suppliers be in full compliance with all applicable governmental, legal, regulatory, and professional requirements. Suppliers are also required to comply with General Cable’s prohibition on employing children, forced labor, indentured labor, involuntary labor, and human trafficking as contained in our Code of Ethics and Business Conduct.
4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
All salaried employees of General Cable are required to complete a Certificate of Compliance at the time of initial employment, then on at least an annual basis thereafter. The Certificate of Compliance states that we have read and understood the Code of Ethics and Business Conduct and have and will continue to comply with our Code, which contains a prohibition on employing children, forced labor, indentured labor, involuntary labor, and human trafficking. Our company investigates all allegations of non-compliance. If allegations are substantiated they are addressed as appropriate and can result in termination.
5. Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
In conjunction with outside counsel having expertise in such issues, General Cable plans to provide employees linked directly to supply chain management with training related to identifying and reporting human trafficking and slavery. To ensure such training will be received by appropriate employees, completion of such training may be tracked by General Cable’s Compliance team. General Cable expects all employees to comply with all applicable laws and regulations in the conduct of our business activities. This extends to laws regarding slavery or human trafficking in the countries in which we do business.
Please telephone +1 877-256-8862 (toll free) or +1 770-582-5269 (direct) if you have any questions or need additional information. For contact information from outside of the United States, please see the General Cable Code of Ethics Web page (http://www.generalcablecsr.com/citizenship/ethics.asp).
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