Legal & Regulatory Compliance
The California Supply Chain Transparency Disclosure. Consistent with Chobani’s commitment to “Nothing But Good”, Chobani is committed to insuring our products are produced and manufactured with ingredients and materials sourced from suppliers that are not engaged or otherwise involved in human trafficking and slavery. The California Transparency in Supply Chains Act of 2010 (SB 657) (“The Act”) seeks the eradication of slavery and human trafficking from product supply chains and requires that companies doing business in California disclose their efforts to ensure that their product supply chains are free from slavery and human trafficking. The Act requires retailers and manufacturers to disclose to what extent, if any, they:
1. Engage 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); and Maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Chobani has instituted an internal verification process. We do not currently use third-parties to conduct supplier verification. Pursuant to our internal verification process our ingredient suppliers and packaging suppliers are asked to confirm to us in writing – in a questionnaire – that they have policies in place to assure that human trafficking and slavery do not exist in their respective organizations and supply chains. In addition, as part of our supplier “qualification” process, each potential supplier must confirm to us in writing that it has anti-human trafficking and anti-slavery policies in place. Supplier responses to our request for confirmation are reviewed. In the event a response is unclear or in the “negative” we will investigate and take appropriate action up to and including termination of our relationship with the supplier.
2. Conduct 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).
Chobani does not currently perform onsite supplier assessments of compliance with responses to our supplier verifications. However, commencing in or about August 2012 supplier assessments will be performed by a third-party to confirm compliance.
3. Require 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.
Chobani’s current annual verification requires confirmation that suppliers have policies in place to assure that human trafficking and slavering do not exist in their organizations or supply chains. We have amended our verification to not only require confirmation that policies are in place to assure that human trafficking and slavery do not exist in a supplier’s organization or supply chain, but also confirmation of compliance with laws regarding slavery and human trafficking of the country or countries in which a supplier does business.
4. Provide 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.
Directors, managers and other members of our procurement and quality assurance departments who are directly responsible for our supply chain management understand and are aware of our requirement that our product ingredients and materials shall not be sourced from suppliers engaged in human trafficking or slavery. All of our employees are required to comply with our company policies. Our commitment to use ingredients and materials sourced from suppliers not engaged or otherwise involved in human trafficking and slavery is no different. Accordingly, as with any alleged violation of company policy, we will investigate the issue and take the appropriate action up to and including termination.
Beginning in or about April 2012, Chobani will provide training to all employees regarding The Act and Chobani’s commitment to insure its products are produced and manufactured only with ingredients and materials sourced from suppliers who are in compliance with local human trafficking and slavery laws.
We will continue to review and update, as necessary, our policies, processes, practices and procedures, and adopt and implement new policies, processes, practices and procedures, in furtherance of our commitment to “Nothing But Good”.