Supply Chain Disclosure Law Catches GCs By Surprise
May 20, 2015
A California law that has been on the books since 2012 requires companies doing business in California to make certain disclosures about their efforts to avoid forced and child labor in their supply chains. The law defines “doing business in California” quite broadly, and the California AG’s office recently sent out a letter to 1700 businesses in a wide variety of industries, asking if they were in compliance and “catching many companies and their general counsels by surprise,” write attorneys from Hogan Lovells in a client alert. The law, called The California Transparency in Supply Chains Act, mandates no substantive requirements regarding sourcing, but it does require that in five areas – including auditing and training – the company make disclosures, even if what the company discloses is that it has taken no action, for whatever reason.
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