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 rights violations.  

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.  

SC Johnson 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 summarized below.

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:

Verification.  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.  

Auditing.  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 and slavery. 

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.

In addition 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 business.  

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.

Training.  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.

Note – 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.