Update on disclosing supply-chain policies under California law

By CMTA Staff

Capitol Update, May 9, 2014 Share this on FacebookTweet thisEmail this to a friend

Are you on the list of companies required to disclose your supply chain policies on the company website? If so, you may soon be receiving a letter from the Attorney General of California (AG) reminding you of your obligation to comply with SB 567 (Darrell Steinberg, D-Sacramento) passed in 2010. The Franchise Tax Board has created a list of companies that must comply – in brief, sellers and manufacturers doing business in California with worldwide gross receipts above $100 million dollars. CMTA does not have access to the confidential list. We believe many companies are not aware of the requirements of the law and will be surprised when they receive the letter. It is also possible that a letter recipient may disagree that they are subject to SB 657.

Compliance under SB 657 means disclosing on company websites the extent to which the company manages its supply chain to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale. Details about who is subject to the law and the information that must be disclosed are available in the law here. We have been told that the AG is beginning this process to both remind companies about their obligation and to provide guidance for compliance. A follow up letter from the AG may be delivered to put a stronger emphasis on compliance given that a first warning has already been given.

CMTA encourages its members to comply with SB 657 and to alert associated businesses and groups about the law. CMTA will be communicating with the AG during their development of guidance. If you are interested in participating in a working group to respond to requests and/or help CMTA in this endeavor, contact Dorothy Rothrock at drothrock@cmta.net.

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