REMINDER: California’s Human Trafficking and Slavery Law Takes Effect January 1, 2012

On January 1, 2012, companies doing business in California that have annual gross global receipts in excess of $100 million will need to comply with California’s Human Trafficking and Slavery Law. The law requires companies to publicly disclose efforts to ensure their supply chains do not support human trafficking or slavery. The bill will have unintended consequences on the electronics industry as the entire supply chain will be questioned and audited regarding their social responsibility practices.

Although the law only directly impacts larger companies, the supply chain will need to provide substantial information and undergo extensive audits. If you think that your company is not impacted because your company doesn’t sell products in the State of California, think again. Your customers in California will likely request information from your company on efforts to eradicate human trafficking and slavery. Because most companies will likely choose to continue conducting business in California, the world’s 8th largest economy, it is expected that the entire electronics supply chain will be impacted. While the disclosure requirements only apply to companies with annual gross global receipts in excess of $100 million, there will be broader implications for the entire electronics supply chain.

The law states the disclosure requirements for companies. Companies must disclose to what extent, if any, they are doing the following:

  • All information on a company’s efforts, if any, to eradicate slavery and human trafficking must be on the company’s webpage. The link to this information must be easy to understand and conspicuously located on the homepage.
  • Performs verification of product supply chains to evaluate and address risks of human trafficking and slavery, including disclosing whether the verification was conducted by a third party.
  • Conducts audits of suppliers to evaluate supplier compliance with company standards for human trafficking and slavery, including disclosing if the audit was not independent and unannounced.
  • Requires direct suppliers to certify that materials incorporated into the product comply with human trafficking and slavery laws of the country or countries in which they are doing business.
  • Maintains internal accountability standards and procedures for employees and contractors failing to meet company standards regarding human trafficking and slavery.
  • 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 supply chains.

IPC held a webinar “Disclosure Requirements That Will Impact the Electronics Industry: California’s Human Trafficking Law” that provided an overview of the requirements, how you will be impacted and what you can do to ensure compliance. This presentation (.pdf, log in required) is available to IPC members free of charge. For more information, please visit IPC’s webpage on corporate social responsibility (CSR) at

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