California Transparency in Supply Chain Act Disclosure
Engrained in its mission to bring health through food to as many people as possible, Danone North America Public Benefit Corporation (“DNA”), the largest Public Benefit Corporation in the United States and a certified B-Corporation, takes great pride in the socially responsible and sustainable manner in which it conducts its business. To that end, and consistent with our commitment to conducting business in an ethical, socially responsible, and lawful manner, DNA supports the eradication of human trafficking and slavery in support of the goals of the California Transparency in Supply Chains Act of 2010 and fully expects its suppliers to conduct their business in the same manner. In furtherance of this effort, DNA has taken the following measures:
Verification of Product Supply Chains
DNA has developed company Sustainability Principles with regard to fundamental social, environmental, and business ethics principles, which include an express prohibition on the use of forced labor or child labor. These standards are incorporated into all of our supply agreements and all of our direct and indirect suppliers are asked to certify their compliance with these standards. DNA also maintains a Code of Conduct for Business Partners, to which suppliers must adhere. Violations of the DNA Sustainability Principles or Code of Conduct may be reported through DNA’s internal alert system the Danone Ethics Line, which may be accessed via www.danoneethicsline.com. All messages are kept strictly confidential and investigated internally.
In addition, except for our milk suppliers which undergo Validus validation, suppliers of a minimum spend must register with SEDEX, a non-profit organization, which manages the largest web-platform and enables suppliers to share responsible and ethical data with their customers. SEDEX provides a supplier risk assessment and audit process to identify at-risk suppliers. If a supplier is identified as at-risk, on-site verifications are conducted by 3rd-party auditors selected by SEDEX. If there are any violations, DNA has the right to terminate the contract. Our milk suppliers participate in the Validus Dairy Animal Welfare Program, which includes a comprehensive third-party audit and assessment of suppliers to ensure adherence to animal welfare, environmental, and worker care standards.
Supplier Audits
DNA requires our suppliers to respect and comply with our Sustainability Principles. DNA is authorized by contract by suppliers in its supply chain to monitor the permanent adherence and implementation of these Sustainability Principles. DNA has free access to audit at any time any of its supplier’s manufacturing and/or warehousing sites, including without limitation, the premises, the plants, the company records, and the complete process of production. In addition, the risk-based audits approach via SEDEX is used to identify at-risk suppliers.
As a condition of doing business with DNA, suppliers must contractually agree to comply with all applicable federal, state, and local laws, government regulations and orders. Supplier’s also warrant that it will adhere to the fundamental social and business ethics principles delineated in the Sustainability Principles, and ensure compliance from its employees, agents, suppliers, and sub-contractors throughout all states of production during the commercial relationship.
Accountability
The highest standards of ethical, moral and lawful conduct are expected from our suppliers and employees. In particular, we expect our suppliers, their agents and their contractors, to be familiar with and comply with all legal and contractual obligations relating to their business activities, and we will not accept any conduct (including by omission) that is unlawful or that violates such obligations. DNA takes seriously any allegations of wrongdoing. Upon learning of any alleged improper conduct, DNA will conduct a prompt and thorough investigation and take those remedial measures deemed appropriate under the circumstances.
Training
The need to evaluate and address the risks of human trafficking and slavery in its product supply chain is part of DNA’s commitment to corporate responsibility and will remain a critical aspect of its supplier management. DNA will continue to require its suppliers, vendors, and employees to comply with its prohibition against slavery and human trafficking. In addition, DNA requires all of its employees to acknowledge and agree to comply with its Code of Conduct and those employees with direct responsibility for procurement are required to participate in the RESPECT responsible sourcing program, which includes education on human trafficking and slavery and recognizing and mitigating risks within the supply chains.