New Disclosure Requirements For Companies Doing Business In California
By: John W. Chierichella
In our February 2009 posting, we commented on the final rule implementing, via FAR 52.222-50 (“Combating Trafficking in Persons”), the Trafficking Victims Protection Reauthorization Act of 2005.
On January 1, 2012, companies doing business in California will have state-level disclosure obligations to deal with in this realm as well. That is the effective date of the California Transparency in Supply Chains Act of 2010, which imposes obligations on every large retailer and manufacturer doing business in California to disclose whether it has taken specified actions to eliminate slavery and human trafficking from its product supply chain.
