Disclosure of RPG Corporation and its divisions and subsidiaries pursuant to California Transparency in Supply Chains Act. RPG Corporation and its subsidiaries (collectively, "RPG", "we”, or "our") believe in the importance of international labor and human rights standards. As a company policy, we do not knowingly employ slaves or trafficked persons. As of January 2012, the employment of slaves or trafficked parties and the participation in human trafficking were expressly added as prohibitions in our Code of Ethics. Pursuant to the requirements of California Transparency in Supply Chains Act, the Company hereby discloses the extent to which it does each of the following:
(1) Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
The Company does engage in verification of product supply chains to the extent it reviews facilities of major suppliers as discussed in (2) below, and in its requirement that suppliers comply with all applicable laws and other legal requirements as stated in (3) below. It does not seek verification specifically to evaluate human trafficking and slavery law compliance of it vendors.
(2) Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
The Company reserves the right to verify our supplier’s compliance with applicable laws. The Company does audit some of its suppliers to evaluate supplier compliance with various laws and ability to meet product standards. These audits are not performed by independent auditors and they are not unannounced.
(3) Requires a direct supplier to certify that materials incorporated into a product comply with slavery and human trafficking laws in the country or countries in which that supplier is doing business.
The Company currently does require in its terms and conditions of purchase from suppliers that suppliers comply with all applicable laws in the production and supply of material purchased. Specific certification is not currently required.
(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Should the Company be made aware of any violation of law by an employee or supplier in the production and supply of material purchased, the Company would have the right to terminate any such employee or supplier agreement.
(5) Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products
The Company has in place policies requiring its associates to comply with all applicable laws. This requirement would apply to laws on human trafficking and slavery. As of January 2012, the employment of slaves or trafficked parties and the participation in human trafficking were expressly added as prohibitions in our Code of Ethics. Currently company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products, are trained to comply with this Company policy.