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California Transparency in Supply Chain Act
The California Transparency in Supply Chains Act of 2010 (the "Act") requires companies that do business in California to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Oreck is in full compliance with this Act.
As an initial matter, when Oreck identifies a new supplier, Oreck retains a third party to conduct an initial facility audit. The auditor prepares a written report for Oreck. The auditor would identify in its report if it believed slavery or human trafficked workers were being used in the facility.
In its standard Supply Agreement, Oreck requires its suppliers to comply with all laws, rules, and regulations. In addition, Oreck provides to its suppliers a Supplier Code of Conduct that suppliers agree to comply with. A supplier that fails to comply with these obligations will be provided notice and an opportunity to correct the noncompliance. If the supplier fails to correct the noncompliance, Oreck will endeavor to find and utilize a new supplier.
Regularly, a multi-departmental team from Oreck will visit and tour various suppliers' facilities. We use a risk-based approach in determining which supplier facility will be visited. In addition to Oreck team members, in foreign countries, we use third party quality audit contractors to conduct site inspections of facilities. Rarely are these inspections unannounced.
Our procurement team members are trained on our supplier code of conduct and our company code of conduct. Team members who violate our code of conduct are subject to disciplinary action up to and including termination of employment.