California Transparency in Supply Chains Act of 2010 Disclosure
Bell Flavors & Fragrances, Inc. (“the Company”) is committed to conducting business in an ethical, lawful, and socially responsible manner. In accordance with the California Transparency in Supply Chains Act of 2010, California Civil Code Section 1714.43 (“the Act”), the Company provides the following disclosures regarding its efforts to address the risks of slavery and human trafficking in its direct supply chain for the tangible goods it offers for sale.
- Verification of Supply Chain Risks
The Company conducts its own verification to evaluate the risks of human trafficking and slavery in its supply chains through supplier qualification and onboarding processes. This verification is conducted internally and not conducted by a third party. All Suppliers are required to:
- Review and self-certify adherence to the Company’s Supplier Code of Ethics and Conduct; or
- Provide their own code of conduct addressing labor and human rights standards, including prohibitions on slavery, forced labor, and human trafficking.
- Supplier Audits
The Company is a participant in the Supplier Ethical Data Exchange (SEDEX). A core principle of Sedex is the avoidance of unfair or unsafe labor practices such as slavery and human trafficking. While the Company does not currently conduct in person audits of its suppliers, the Company maintains supplier due diligence processes that include the review of third-party audit reports provided to the Company by suppliers in response to the Company’s annual requests.
Suppliers are requested on an annual basis by the Company to provide evidence of a current, valid audit conducted by an independent third-party organization (e.g., SEDEX, EcoVadis, or comparable programs), which assess ethical, social, and environmental performance, including labor and human rights risks.
The Company does not currently conduct its own independent audits of suppliers. Instead, it relies on supplier-provided third-party audit reports. Such audits are conducted on an announced basis. The Company does not conduct independent unannounced audits of its suppliers.
- Supplier Certification
The Company requires direct suppliers to:
- Adhere to standards prohibiting slavery, forced labor, human trafficking, and the exploitation of workers;
- Maintain compliance with all applicable labor and employment laws in the countries in which they operate; and
- Certify that the materials incorporated into the products they supply to the Company comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
The Company requires all direct suppliers to self-certify adherence to these tenets by signing the Company’s Supplier Code of Ethics and Conduct or, as described in Section 1 above, by providing their own code of conduct addressing these standards.
- Internal Accountability Standards
The Company maintains internal policies and procedures designed to promote ethical conduct and compliance with applicable laws and human rights standards.
Failure by employees or contractors to comply with Company policy regarding slavery and trafficking can result in corrective action or termination. In addition, the Company reserves the right to terminate a business relationship with a contractor or supplier or customer for violation of these policies.
- Training
The Company provides annual training on ethical business practices, including human rights expectations and the prohibition of forced labor, child labor, and human trafficking.
Such training is provided to all employees and managers, including those employees and managers who have direct responsibility for supply chain management, and addresses mitigating the risks of slavery and human trafficking within the supply chains of the Company’s products.
Commitment to Ethical Conduct and Legal Compliance
The Company is committed to conducting its operations in compliance with applicable local, state, federal, and international laws and regulations, including those relating to labor, employment, health and safety, environmental protection, and human rights.
The Company does not tolerate slavery, forced labor, or human trafficking in any part of its business or supply chains and expects its suppliers and business partners to uphold the same standards.