Corporate Responsibility

August 3, 2015

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

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) took effect in the State of California. The Act seeks the elimination of slavery and human trafficking from product supply chains and requires that companies disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

SMC Ltd. (“SMC”) is dedicated to conducting business in a lawful and ethical manner and supports human rights, ethical labor practices, and environmental protection standards.

In support of the California Transparency in Supply Chains Act of 2010 (SB 657), SMC will uphold our commitment through the following practices:

  1. Risk Assessments: SMC continues to evaluate the risk of our suppliers being involved in slavery or human trafficking. Attention will be paid to suppliers that provide goods or services that are listed on the “List of Goods Produced by Child Labor or Forced Labor” as published by the Office of Labor, Forced Labor, and Human Trafficking. Current suppliers who may be at high risk will be contacted to make them aware of the California Transparency in Supply Chains Act of 2010 (SB-657). In addition, new suppliers are asked to state that they are in compliance with the California Transparency in Supply Chains Act of 2010 (SB 657) when they complete a Supplier Self Survey form. This verification is conducted by SMC Ltd. employees and not by a third party.
  2. Auditing: SMC performs audits as required.
  3. Certification Requirement: SMC prefers to source its raw materials from domestic suppliers, and the company expects all suppliers to abide by applicable federal, international and local laws, rules, and regulations in the manufacture and distribution of materials supplied. However, we do not presently require our suppliers to certify their materials. Although we do require our suppliers to maintain records to substantiate that all materials it supplies are produced in compliance with the anti-slavery and human trafficking laws of the country or countries in which they operate. Such records may include written policies and procedures that ensure adherence to all elements of the Act, as well as personnel files for every worker, including proof of age, executed employment contract (where necessary by law), and a true and accurate record of hours and wages.
  4. Employee Standards of Conduct: SMC requires that all employees act in a responsible and ethical manner in all activities in the workplace. All activities are governed by honesty, fair dealing, integrity, and full compliance with all applicable laws and regulations. Any employees not adhering to this policy will be subject to disciplinary action up to and including termination of employment.
  5. Employee Training: SMC conducts training for employees whose job functions include procurement that emphasizes the importance of ensuring SMC’s supplier base abide by the California Transparency in Supply Chains Act of 2010 and its prohibition on slavery and human trafficking.