ATEST Comments and Suggestions on the California Attorney General’s Office’s Company Notification Letter and Resource Guide
The California Transparency and Supply Chains Act (“the Act”), enacted in 2010, requires large retailers and manufacturers doing business in California to disclose on their websites their “efforts to eradicate slavery and human trafficking from [their] direct supply chain for tangible goods offered for sale.” The law is designed to assist consumers in their purchasing decisions by providing them with essential information about the efforts that companies are undertaking to prevent human trafficking and forced labor in their product supply chains, both in California and overseas.
By letter dated April 1, 2015, the California Attorney General’s Office notified all of the companies it determined to be subject to the Act’s requirements of their reporting obligations through a document it entitled, “Informational Letter to Companies.” Shortly thereafter, it issued a Resource Guide “intended to help covered companies by offering recommendations about model disclosures and best practices for developing such disclosures.”
As an original sponsor of the Act, ATEST applauds the Attorney General’s efforts in implementing the law through these publications. The Informational Letter clearly alerts companies of their responsibilities under the Act and apprises them of the Attorney General’s enforcement authority. The Resource Guide not only provides a comprehensive review of the Act’s purpose and reporting obligations, but also gives detailed examples of model disclosure language, as well as unacceptable submissions, for each of the five main substantive reporting rubrics. Both of these documents, and the resources referenced in them, are valuable tools for entities seeking to meet and even go beyond the Act’s reporting requirements.
The comments and suggestions in this document are intended to build on the well-crafted foundation provided by the Attorney General’s earlier publications. ATEST offers them in the spirit of further realizing the Act’s fundamental goals of educating consumers about the anti-trafficking efforts of companies doing business in California and ensuring that goods sold in California are not tainted by slavery. We look forward to working in partnership with the Attorney General in modifying and refining these documents as continued review of the subject companies’ published disclosure statements provides further insight into the dynamics of the reporting process.
Read the full comments and suggestions here: ATEST-Comments-on-CA-AG-Resource-Guide-FINAL-September-21-2015