Transparency in Supply Chains Act Disclosure
Purpose
This disclosure is provided pursuant to the California Transparency in Supply Chains Act of 2010, which went into effect January 1, 2012.
General Position
AMCOR supports efforts to eradicate forced labor, slavery, human trafficking and child labor violations (collectively “Prohibited Conduct”), and believes that all companies should be taking reasonable actions to manage their product supply chains to promote such goals. AMCOR believes that any particular action it may take, and the time period within which such action may be taken, will vary and change from time to time. AMCOR has implemented certain processes to promote social responsibility by its material suppliers within its direct supply chain for products (each a “Supplier” and collectively “Suppliers”).
Disclosure
In compliance with California Civil Code Section 1714.43 (the California Transparency in Supply Chains Act of 2010) AMCOR hereby makes the following disclosures:
Verification: AMCOR has a formal program that proactively verifies that its Suppliers are not engaging in Prohibited Conduct, as well as an internal program aimed at increasing awareness and prevention of Prohibited Conduct in its Supply Chain. This program includes training for its employees involved in selecting, qualifying and managing Suppliers to assist those employees in identifying Suppliers at risk of engaging in Prohibited Conduct. If AMCOR receives information causing it to suspect that a Supplier may be engaging in Prohibited Conduct, it will investigate and take such action as it deems reasonable and appropriate under the circumstances, including but not limited to ending a Supplier relationship if necessary. AMCOR also currently uses a third party assessment program for Prohibited Conduct verification purposes.
Auditing: AMCOR does not currently have a formal program of proactive audits of potential and current Suppliers with respect to Prohibited Conduct. However, AMCOR has formally adopted the “AMCOR Suppliers Code of Conduct” (“Code of Conduct”) which, among other things, sets forth AMCOR’s commitment to buy from only those Suppliers that can affirm that they do not use or benefit from forced labor, slavery or child labor. AMCOR’s Code of Conduct also requires its Suppliers to affirm that that they operate in compliance with the applicable laws and regulations of the jurisdictions within which they do business. Finally, AMCOR typically includes a representation in its contracts with its Suppliers indicating that the Supplier will comply with applicable laws and regulations of the jurisdictions in which they operate. AMCOR does not conduct independent or unannounced audits at this time.
Certification: AMCOR’s Code of Conduct requires its Suppliers to certify that they do not use or benefit from forced labor, slavery or child labor. The Code of Conduct further requires AMCOR’s Suppliers to affirm that they operate in compliance with the applicable laws and regulations of the jurisdictions within which they do business, and AMCOR typically includes a representation in its contracts with its Suppliers to this effect as well. AMCOR includes a certification in supply relationship documentation that materials incorporated into any product sold to AMCOR have been produced in compliance with the laws regarding slavery and human trafficking of the country or countries in which the Supplier conducts business.
Internal Accountability: In the event an employee or Supplier engages in, or fails to address, known Prohibited Conduct, any consequences will depend on the nature, circumstances and context of the act or omission. Consequences may include any or all of the following: termination of an existing contract or supply arrangement with a Supplier; non-renewal of an existing supply arrangement with a Supplier; increased reporting or other requirements on a Supplier; more stringent verification or audit obligations; more stringent cure or performance obligations; a claim for breach of contract and damages; requiring additional education or disciplinary action, up to and including termination (for an employee).
Training: AMCOR provides ongoing training to its employees and managers who have direct responsibility for supply chain management. Training addresses identifying risks of Prohibited Conduct, characteristics to watch for when selecting or qualifying prospective Suppliers, and evaluating the performance of Suppliers.
Scope of this Disclosure:
Limitations The disclosures contained on this link are made as to the current actual knowledge of AMCOR as of 2016.
Questions or Compliance Information
Persons having questions or concerns regarding AMCOR’s supply chain management and compliance with the California Transparency in Supply Chains Act of 2010, should contact AMCOR’s General Counsel at +1 734 428 9741.
