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California Publishes Transparency in Supply Chains Guide

The California Department of Justice recently released a guide, The California Transparency in Supply Chains Act: A Resource Guide, to provide businesses with recommendations on how to develop required disclosures pertaining to their efforts to prevent human trafficking. The disclosures are mandated by the California Transparency in Supply Chains Act of 2010 (the Act), which requires manufacturers and retailers doing business in California—with annual gross receipts that exceed $100 million—to inform the public about their "efforts to eradicate slavery and trafficking in their direct supply chains for tangible goods offered for sale."

There are five subject areas that must be covered by the disclosures: verification, audits, certification, internal accountability, and training. The Resource Guide discusses how a company can structure their disclosures to comply with the law in each category. All disclosures must be posted on the company's website and accessible by a link on the homepage. If a company subject to the law does not have a website, it must provide written disclosures within 30 days of receiving a written request for the information.

The Act does not dictate that businesses must implement new measures to ensure that their product supply chains are free from human trafficking and slavery; rather, the law requires only that covered businesses make the required disclosures.