California Transparency in Supply Chains Act of 2010 (SB 657)

The California Transparency in Supply Chains Act of 2010 (SB 657) requires retail sellers and manufacturers doing business in the state of California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Flint Group’s Code of Conduct specifically condemns all kinds of child labor as well as forced or compulsory labor. This includes any type of human trafficking or slavery.

Flint Group enforces the following processes to protect against slavery and human trafficking in our supply chain:                                    

• Risk evaluation - Verification of product supply chains using risk-based supplier assessment techniques. This includes preliminary risk assessments which are conducted by Flint Group personnel to assess the likelihood of potential rights violations. The risk assessment evaluates factors such as supplier location, NGO reports/findings, procurement category and responses obtained from the Flint Group supplier assessment questionnaires.
  
  
• Audit - Flint Group personnel selectively audit our direct suppliers for compliance with the Flint Group supplier assessment questionnaires. Included in these questionnaires is a sustainability section supporting the ten principles of the United Nations Global Compact including those related to human rights and labor (http://www.unglobalcompact.org/Issues/index.html). These audits are documented and managed globally.
  
  
• Certification – Flint Group requires that direct suppliers document their level of compliance with applicable laws and regulations regarding forced labor as specified in the Flint Group assessment questionnaires. We stress this with employees as well. Flint Group’s Employee Representation Certification program is used internally to monitor for awareness of—and support a united stance against—child labor or forced or compulsory labor used by the Company or any of our suppliers. This certification is reviewed and reconfirmed annually by all procurement personnel and company management personnel.
  
  
• Accountability – Flint Group employees found to be in violation of the company's Code of Conduct may face disciplinary action up to and including immediate termination of employment and report to the proper authorities as may be required.  If supplier/contractor violations are discovered, Flint Group will implement all reasonable measures to rectify the situation.
  
  
• Training – Flint Group procurement personnel have received guidance on these issues as part of the supplier questionnaire implementation process. The company is currently evaluating additional courses specifically developed for supply chain staff members that address awareness, identification, prevention and mitigation efforts of human trafficking and slavery.