California Transparency in Supply Chains Act of 2010
DrinkPAK, LLC (“DrinkPAK” or the “Company”) is committed to conducting its business according to the highest ethical and legal standards. DrinkPAK does not knowingly employ any type of involuntary labor and will not knowingly conduct business with any vendor that uses involuntary labor of any kind, including prison labor, indentured labor, bonded labor, or labor obtained through human trafficking or slavery. DrinkPAK requires all of its vendors and suppliers to comply with all applicable laws and regulations of the United States, as well as those of the country of manufacture and exportation. DrinkPAK also prohibits its vendors and suppliers from using slave, forced, prison or child labor, and expects them to prevent practices that could in any way contribute to human trafficking.
The California Transparency in Supply Chains Act of 2010 (the “Act”) requires retailers and manufacturers doing business in California to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. The purpose of the Act is to increase the amount of information available to consumers about the efforts manufacturers and retailers are undertaking to prevent and eradicate human trafficking and slavery in their product supply chains, both in the United States and in international markets. The Act requires company disclosures in five (5) areas – verification, audit, certification, internal accountability, and training.
At this time, DrinkPAK has taken the following actions related to (i) verification of product supply chains to evaluate risks of human trafficking and slavery; (ii) conducting audits of suppliers to evaluate compliance with DrinkPAK standards on human trafficking and slavery; (iii) requiring direct suppliers to certify that their products comply with laws against human trafficking and slavery; (iv) maintaining internal procedures for employees and contractors who fail to meet DrinkPAK standards; and (v) providing training on mitigating the risks of human trafficking within the supply chain.
Verification:
We are committed to fair labor practices within our supply chain. DrinkPAK uses various tools to verify that its suppliers operate fairly and safely and address the risks of human trafficking and slavery. DrinkPAK onboards all suppliers through utilization of the DrinkPAK Supply Chain Program and Supplier Assessment Procedures (the “Procedures”) including a Supplier Documentation Request which requires in part that all vendors (“Vendors”) submit a California Transparency in Supply Chains Act of 2010 statementto verify that they are not at risk for violating anti-slavery and human trafficking laws when they are onboarded. Our own senior management team spearheads the verification process using an internally developed rubric and multi-part assessment. We do not use third-party verifiers to independently verify whether our subcontractors use labor brokers. DrinkPAK does not knowingly employ any type of involuntary labor and will not knowingly conduct business with any Vendor that uses involuntary labor of any kind. DrinkPAK does this by requiring all Vendors to comply with the Procedures, which is a requirement of doing business with DrinkPAK.
Audits:
Pursuant the Procedures, DrinkPAK requires updated documentation annually for all dated documents and at least every five years for undated documentation. DrinkPAK determines which Vendors to audit based on specific risk assessments as well as the results of previous audits and other information obtained by DrinkPAK.
Certification:
In any situation where a new product or new materials are introduced into the DrinkPAK system, the Vendor must undergo an approval process to assure they can provide safe products or materials. No products or materials may be ordered until the approval process has been completed. DrinkPAK requires all Vendors in its supply chain to comply with the Procedures. To evaluate compliance with the Procedures, see the Audit section above. DrinkPAK is always reviewing and monitoring its Vendor relationships, and any found in violation of DrinkPAK Procedures may be terminated.
Internal Accountability:
DrinkPAK seeks to do business with Vendors that share DrinkPAK’s commitment and dedication to ethical and responsible business practices, and we encourage Vendors to promote best practices and to work towards continual improvement through their production operations and supply chains. DrinkPAK reviews and monitors its Vendor relationships and may terminate a relationship with any Vendor found to be in violation of DrinkPAK’s Procedures. DrinkPAK is continuously working to implement an enhanced compliance program to ensure all employees and supply chains comply with all respective laws and DrinkPAK’s standards regarding human trafficking, slavery, and child labor in supply chains.
Training:
At this time, DrinkPAK has not taken specific actions related to training.
While this disclosure outlines DrinkPAK’s standard supply chain procurement practices and contracting provisions, exceptions may exist or occur.