Hogan Lovells International Trade Alert- California Enforces Supply Chain Disclosure Law.pdf

Dear JPA Members:

Staff is writing to alert those with business interests in California that the state Attorney General's (AG) office is enforcing the California Transparency in Supply Chains Act, which went into effect on January 1, 2012.

By way of background, this law seeks to acquire public information from retailers and manufacturers regarding voluntary efforts to eliminate slavery and human trafficking from their product supply chains. Any company that identifies as a retailer or manufacturer on its California tax return and/or earns more than $100 million in annual worldwide gross receipts must comply with the law. In 2011, JPA advised members of this law’s development, provided examples of required disclosure statements and hosted conference calls for members to discuss compliance.

In May 2015, more than 1,700 letters were issued to companies, requiring them to notify the AG’s office that they are, or are not, in compliance with the law. Traditionally, the law has not been strictly enforced in the manufacturing sector, with most attention focused on retailers. Thus, California's sudden enforcement has therfore caught many companies, in a wide array of industries, off guard. For more information on the disclosures required, please view the enclosed update from JPA Legal Counsel, Hogan Lovells US LLP. Sample disclosure statements are also posted on the members only section of the JPA website. Under the Document Library, simply enter "statement" in the keywords field and the statements will appear. These statements are from JPA member companies and may serve as “best practices” for compliance with the law.*

JPA will continue to monitor this issue and keep members apprised of developments. Please let us know if you have any questions.

*The posting of these disclosures does not imply endorsement of these statements by JPA. Each member company should have its legal counsel advise as to the disclosure statement that will ensure its compliance with the requirements of the California Transparency in Supply Chains Act of 2010.

JPA Updates & News Scans are provided as a service exclusively to JPA members. Please do not share these communications outside the membership.

JPA Staff
529 14th St. NW, Suite 750
Washington, DC 20045

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