The California Transparency in Supply Chains Act of 2010 (SB 657) requires retailers and manufacturers who do business in the state of California and have annual gross worldwide sales over $100 million to be transparent about the efforts they have undertaken to eradicate slavery and human trafficking in their supply chain. In order to be compliant companies in scope of the law are required to publically disclose the extent to which they (1) verify their product supply chains to evaluate and address risks of human trafficking and slave labour, (2) conduct audits to evaluate their suppliers’ compliance with company standards, (3) require their direct suppliers to certify that materials used to make their products comply with the laws regarding slavery and human trafficking of the country(s) in which they are doing business (4) maintain internal accountability standards for employees or contractors that fall short of company requirements and (5) train employees who are responsible for supply side management on human trafficking and slavery, with a focus on the risks within supply chains.
As a member of the Electronic Industry Citizenship Coalition (EICC) Pace demonstrates its commitment to environmental and social responsibility. We have adopted the EICC Code of Conduct which provides that adopters must not use forced, bonded, indentured or prison labour, that work shall be voluntary and that workers shall be free to leave their employment upon reasonable notice.
In addition the Pace Code of Business Ethics supply chain policy is based on international labour and human rights standards. We partner with our supply chain to create an environment where workers have the right to freely choose employment, the right to associate freely, voluntarily join or not join labour unions and worker councils, and the right to bargain collectively if they choose.
Pace supply chain partners and suppliers must, as a minimum, adhere to the EICC Code of Conduct. We audit our suppliers to this code and take seriously all forms of non-conformance.
We operate a programme of assessment and auditing and review status and progress at the regular business review meetings held with our principal suppliers. Our commitment as members of EICC is to work with our suppliers on a continuous improvement basis.
We use the EICC Self-Assessment Questionnaire (SAQ) to ensure consistency and to drive to industry-recognised standards. Several of our suppliers are members of the EICC.
We undertake auditing of our suppliers and members of the quality team have received social auditing training. Two members of the team are certified EICC-GeSI Labour and Ethics Lead Auditors. We conduct the audits directly and they are announced.
If a supplier fails to live up to our standards, including those contained in the EICC Code of Conduct with respect to freely chosen employment, we may terminate our engagement with them.
The EICC has a Freely Chosen Employment (FCE) task force designed to help identify opportunities to share best practices among members, expand the Code of Conduct, and make recommendations on available tools and training. A member of the Pace quality team is a member of the task force. Pace is working within the guidance provided by the task force.
Pace has an ongoing internal programme which is helping to ensure that Pace employees who are responsible for supply chain management including quality, procurement and operations teams develop awareness and an understanding of the issues of human trafficking and slavery, particularly with regard to risks within the supply chain.