The California Transparency in Supply Chains Act of 2010 (the “Act”)
seeks to eliminate slavery and human trafficking from global supply
chains by requiring companies that do business in California to disclose
what efforts they take to keep their supply chains free of these human
As a leading global corporate citizen and consistent with the principles codified in 1976 in This We Believe,
SC Johnson has a zero-tolerance policy for human trafficking or slavery
in our supply chain. SC Johnson unequivocally supports the human rights
of all of our employees, and the employees of our global suppliers. We
support the United Nations Declaration of Human Rights and the
International Labor Organization core standards on forced labor, child
labor, freedom of association, and discrimination.
also supports the intent of the Act. The company addresses the concerns
underlying the Act through our Supplier Code of Conduct (referred to
with SC Johnson suppliers as the “Manufacturing Code of Conduct”) and
the practices it requires. Key elements of those practices are
SC Johnson expects our suppliers to adhere to
the standards set out in our Supplier Code of Conduct, which addresses
the following labor and human rights issues:
• Prohibition of
forced labor – suppliers may not use forced labor in any form, whether
prison, indentured, bonded or otherwise.
• Minimum age
requirement – suppliers may not employ any person below the age of 16
and, where local standards are higher, suppliers may not employ a person
under the legal minimum age.
• Compensation and minimum wage requirements – suppliers must provide each employee at least the minimum wage
• Legally mandated benefits – suppliers must provide each employee, at a minimum, all legally mandated benefits.
• Maximum work hours – suppliers must comply with legally mandated work hours.
Environmental, health and safety requirements – suppliers must have
written safety, health and environmental guidelines, comply with local
safety, health and environmental laws and regulations, and provide
personal protective equipment.
• Immigration/qualified to work
laws – suppliers must comply with applicable immigration and related
laws to ensure that employees may work in the country where the
employees are providing services.
In support of what is laid out in the company’s Supplier Code of Conduct, SC Johnson also undertakes the following steps:
SC Johnson uses internal resources to evaluate potential suppliers
across a variety of factors, and if we become aware of human trafficking
or slavery concerns, we would not work with the supplier. Additionally,
our major suppliers are required to sign the SC Johnson Supplier Code
of Conduct as part of our supply agreements.
SC Johnson’s Supplier Code of Conduct allows us to conduct unannounced
audits, with either SC Johnson personnel or independent third parties,
to verify compliance with our standards. We conduct audits that address
safety, environmental and quality standards, and in 2012 those audits
will be expanded to include additional information on human trafficking
Certification. All SC Johnson
suppliers that have signed our Supplier Code of Conduct must certify, by
contract, that the goods and services they provide to the company are
manufactured in compliance with those standards, and with all applicable
laws and regulations in the jurisdictions in which they are produced.
In addition, our purchase orders contain requirements that suppliers
will comply with all applicable laws and regulations.
to our general requirements regarding compliance with laws, as part of
the ongoing review and enhancement of the Supplier Code of Conduct,
beginning in 2012, SC Johnson will include a section that specifically
requires our suppliers to certify that the materials they use in our
products comply with the appropriate local laws regarding slavery and
human trafficking of the country or countries in which they are doing
Internal Accountability Standards. If
any employee or supplier fails to comply with any aspect of the
company’s Supplier Code of Conduct, SC Johnson takes the appropriate
remedial actions. If the non-compliance is serious enough, or if
appropriate corrective actions are not taken, SC Johnson can terminate
the relationship with the employee or supplier.
Those employees responsible for supplier contracts, including
Procurement Managers, are familiar with SC Johnson’s Supplier Code of
Conduct. During 2012 we will be expanding the information provided to
those employees on human trafficking and slavery.
Although the vast majority of our purchases are subject to suppliers’
contractual commitments to abide by our Supplier Code of Conduct, we
intend to continue to increase the amount of our purchases that are
contractually subject to our Supplier Code of Conduct.