CA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURES
We believe that we have a responsibility to conduct our business in an ethical and sustainable way and expect the same from our suppliers, thus we strive to build long-term business relationships that demonstrate a commitment to fair treatment of workers and environmental responsibility. This includes working to eradicate slavery, human trafficking, and child labor from our supply chains.
As a large producer of dairy products in the United States, we are committed to conducting business in an ethical, socially responsible, sustainable, and lawful manner. We recognize the critical importance for business integrity, fairness, ethical conduct, and compliance with all laws and regulations affecting our business dealings. We expect our employees, suppliers, and contractors to always adhere to the letter, spirit, and intent of these expectations and values as well as all applicable laws and regulations, including those prohibiting involvement with human trafficking and slavery. Everyone who is part of our business community, whether an employee, contractor, or supplier, is held accountable to conduct business with or for us in an ethical manner.
Our employees are, under the terms of their employment, required to follow applicable laws and regulations, along with our code of business ethics, policies and procedures, employee manuals, and various business rules and standard operating procedures. Non-compliance by employees may result in discipline, up to and including termination.
Our Standards of Conduct applicable to all employees outlines our commitment to uphold our standards and commitments. Similarly, our Supplier Code of Conduct, sets forth publicly our expectation that our suppliers adhere to the same standards and commitments.
We informally monitor our supply chain and assess potential suppliers in an effort to detect any issues, though we do not always conduct formal audits. We engage in various activities to identify, assess, and manage supplier risk. Our suppliers generally undergo health, safety, and environment (HSE) risk assessments and a rigorous qualification process as managed by our internal Supplier Quality Assurance team prior to awarding supply contracts. In addition, our current standard commercial contract provisions require suppliers to comply with all applicable laws and regulations, and compliance with our current Supplier Code of Conduct is also being incorporated, to ensure that our suppliers respect and abide by our standards. Compliance certifications from suppliers may be required. Regardless of whether a certification is required, however, a supplier’s failure to comply with applicable laws and regulations generally would constitute a breach of contract subject to termination of such contract, particularly if it fails to address contractual non-compliance in a timely manner. In addition, a supplier’s failure to adhere to our expectations and/or its engagement in conduct or activities that are contrary to our standards and commitment, including non-compliance with our Supplier Code of Conduct, may result in our auditing the supplier’s facilities and/or ceasing our business relationship with that supplier. We will not knowingly do business with any supplier that supports, condones, or otherwise has issues with slavery, human trafficking, and/or forced labor, or other forms of coercion, fraud, deception, abuse of power, or other means to control people in order to exploit them. As part of our supply chain sustainability program, we will continue to develop and strengthen processes that hold suppliers accountable in these and other related areas.
We train our employees in the standards of ethical behavior, policies, procedures, and legal requirements that define the way we do business. All employees with direct responsibility for supply chain risk assessment, quality, and/or auditing are expected to adhere to our strict ethical practices, especially as they relate to supply chain management and mitigation of risks within the supply chains of products. Our internal training programs that emphasize our expectations and encourage best practices continue to be developed.
We maintain internal controls and accountability standards and procedures for employees and/or contractors failing to meet company standards. One important accountability mechanism is our ethics and compliance hotline that can be used by employees and/or contractors by emailing firstname.lastname@example.org, calling 1-833-270-0009, or faxing a report to (215) 689-3885 (the “Compliance Hotline”). Employees, suppliers, and contractors may communicate workplace concerns through the Compliance Hotline 24 hours per day, seven days per week. The Compliance Hotline provides a direct, effective, and risk-free way to report suspected violations of our codes of conduct, company policies, and/or applicable laws and regulations.