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.
For a comprehensive analysis of the California statute, its applicability to companies that are neither organized nor domiciled in California, the disclosure obligations it imposes, remedies, how companies can and should respond to the statute, and the public relations implications of a minimalist approach to compliance, click here to link to an article recently authored by Peter Menard of Sheppard Mullin’s Los Angeles office and published in the California State Bar’s “Business Law News.” If you have questions in this area, Peter can be reached directly at firstname.lastname@example.org or at (213) 617-5483.
John W. Chierichella