Corporate Social Responsibility

California Transparency in Supply Chains Act (SB 657)

Referred to as SB 657, the California Transparency in Supply Chains Act adds to the existing federal Victims of Trafficking and Violence Protection Act of 2000. Existing state law makes human trafficking a crime; it allows a victim of human trafficking to bring a civil action for actual damages, compensatory damages, punitive damages, injunctive relief, any combination of those, or any other appropriate relief. Existing law generally regulates various business activities and practices, including those of retail sellers and manufacturers of products. Swanson Health Products is committed to compliance with the declaration requirements of SB 657, the California Transparency in Supply Chains Act of 2010, which requires retail sellers and manufacturers doing business in the state of California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale effective January 1, 2012. In addition, Swanson is committed to developing and upholding a policy regarding human rights issues and requiring the same commitment of its suppliers.

The points outlined below in bold highlight each of the five pillars of the California Transparency in Supply Chains Act, followed by an explanation of Swanson Health Products (SHP) status regarding each pillar.

• Company engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. This disclosure shall specify if the verification was not conducted by a third party.
• The majority of SHP’s direct supply chain business partners are US companies; many of these direct suppliers have been visited and/or audited by SHP personnel, but this was not conducted by a third party. No human trafficking risks have been identified by SHP personnel during those visits.
• Company conducts 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.
• The supplier audits that have been conducted at SHP to date have not specifically addressed compliance with human trafficking and slavery standards, although the companies have all been in areas not known to have such problems. The audits were not conducted in an independent, unannounced audit.
• Company requires 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.
• SHP does not currently require direct suppliers to certify that materials incorporated into the product comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business.
• Company maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
• SHP does not currently maintain internal accountability standards and procedures beyond the United States Universal Declaration of Human Rights for employees or contractors failing to meet company standards regarding slavery and trafficking.
• Company provides 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.
• SHP employees who have direct responsibility over supply chain management have general knowledge regarding the company’s desire to mitigate risks of human trafficking and slavery within the supply chains of products.

SHP Human Rights and Responsibilities

Swanson Health Products is committed to conducting business in an ethical and responsible manner. It is Swanson Health Products’ priority to safeguard the rights of our employees and those of the workers who manufacture our products or work in the supply chain. Swanson Health Products’ suppliers are expected to conduct their operations in a socially responsible manner.