California Transparency in Supply Chains Act (SB 657) – Disclosure
Although slavery was officially abolished all over the world since 1980, the slave trade is still present on every continent. Refusing to be an accessory to any form of slavery or human trafficking and in accordance with the California Transparency in Supply Chains Act, Cummins Allison is adopting a zero tolerance approach towards slavery and human trafficking in its supply chains:
Verification of product supply chains
Cummins Allison archives the statements on human trafficking / slavery it receives from its suppliers for new components used in its products.
Audits of suppliers
Cummins Allison has not identified significant risks with direct suppliers that would require the conduct of supplier audits.
Certifications from direct suppliers
For any component used in the manufacture of its products, Cummins Allison systematically asks its suppliers to provide a statement of compliance to applicable slavery and human trafficking laws.
Each Cummins Allison employee and consultant agrees to fulfill their assigned tasks in accordance with applicable laws and the principle of respecting human rights. In the event Cummins Allison becomes aware of a violation, management will take the appropriate measures, which can extend to the dismissal of the employee.
Cummins Allison informs and trains those employees and managers that have a direct role in supply chain management. The objective is to develop awareness and understanding of the issues of human trafficking and slavery in supply chains and to ensure that verification of the supply chains is done in accordance with Cummins Allison's procedures.
Conflict Minerals Policy Statement
In July 2010, the Wall Street Reform and Consumer Protection Act was signed into law, also known as the Dodd-Frank Act (the "Act"). Although the focus of the Act is financial market regulatory reforms, it also imposes requirements relating to "Conflict Minerals". Specifically, section 1502 of the Act imposes Security and Exchange Commission ("SEC") reporting requirements upon publicly-traded companies whose products contain metals derived from minerals defined as "Conflict Minerals". "Conflict Minerals" refers to specific mineral ores and their derivatives (gold, tantalum, tin, and tungsten) which originate from Democratic Republic of the Congo ("DRC") or specified adjoining countries.
The new reporting requirements reflect Congressional concern that revenues obtained from mining and transport of "Conflict Minerals" finance the ongoing conflict in the DRC and surrounding countries and the resulting humanitarian crisis.
Cummins Allison, as a privately held corporation, is not subject to the Conflict Minerals reporting requirements; however, as a supplier to publicly-traded companies, we are committed to helping our customers comply with their reporting requirements. In addition, Cummins Allison is fully supportive of global industry efforts to ensure responsible manufacturing processes with transparent sourcing in full accordance with the law.
The Act requires publicly-traded companies to report annually to the SEC on (a) their worldwide use of "Conflict Minerals" in products they manufacture or contract to manufacture, and (b) the cooperation of their supply chains in identifying the use of "Conflict Minerals"; identifying the country of origin for any tantalum, tin, tungsten, and gold; and determining whether "Conflict Minerals" from the DRC region are "conflict free" (that is, they do not directly or indirectly finance armed groups through mining or mineral trading in the DRC Region).
Supplier cooperation will be needed to get information from smelters/refiners (the choke points in identifying the source of the minerals) in their supply chain as to whether products contain "Conflict Minerals" that originate in the DRC or adjacent countries. Note that these requirements will apply equally to U.S. and non-U.S. suppliers.
Annual submissions to the SEC will under certain circumstances require an independent, third-party audit, and therefore proper documentation of information related to your supply chain is critical.
Just as Cummins Allison is doing, it is important that our suppliers examine their supply chain and consult with their suppliers to verify that no "Conflict Minerals" are included in any of their products. Working together is the only approach that will enable everyone subject to these requirements to accomplish this task.