California Supply Chains Act

California Transparency in Supply Chains Act Disclosure

OSI Group, LLC supports the goals of the California Transparency in Supply Chains Act of 2010 (“Act”) and strives to continually improve our processes and practices to maintain high standards in the ethical sourcing of materials used in our products. Our efforts so far in aligning with the Act’s requirements include the following:

Certifications by Direct Suppliers

To help assure our procurement is free from slavery and human trafficking, our supply agreements incorporate language requiring suppliers to warrant compliance with the Act and any known violation may result in immediate termination of the agreement.

Further, the OSI Supplier Code of Conduct makes clear our commitment to fair labor standards and our expectation toward our suppliers to share this commitment. This Supplier Code of Conduct requires our suppliers to adhere to certain principles and practices, including workplace safety, equal employment opportunities and fair employment practices prohibiting child labor, forced labor, or any form of slavery or human trafficking.

The Supplier Code of Conduct is embedded into our procurement practices as follows:

• All new suppliers are required to acknowledge the Supplier Code of Conduct as part of their onboarding process;
• A link pointing to OSI purchase order terms and conditions and the Supplier Code of Conduct  is referenced in each SAP system-generated purchase order, allowing our suppliers access to a website that uploads the latest version of the Supplier Code of Conduct; and
• When necessary, a hard copy of the latest version of the Supplier Code of Conduct is issued to our current supplier community.

Verification and Audits of Product Supply Chains

In addition to our supply contracts and Supplier Code of Conduct, we are now designing a risk-based verification process to identify high-risk suppliers and developing an appropriate responsible-sourcing audit approach to ensure our product suppliers are in compliance with our Supplier Code of Conduct.

OSI reserves the right to audit our suppliers’ compliance with the Supplier Code of Conduct by OSI or its approved third party. If an audit identifies a violation of the Supplier Code of Conduct, OSI reserves the right to demand prompt corrective measures by our suppliers to OSI’s satisfaction and the right to terminate any and all business if not corrected on a timely basis.

Internal accountability standards

At OSI, we are committed to conducting business with the highest integrity and in compliance with all applicable laws and regulations. Our employees are expected to adhere to the principles described in our Global Business Standards. The principles stated in our Global Business Standards apply to all aspects of our business, including those pertinent to entitlement to work, ethical sourcing and partnering with suppliers who act as good corporate citizens. Violators are subject to disciplinary action, up to and including termination of employment.

Employee Training

In 2011, we rolled out an online training program for our Global Business Standards to our management employees worldwide. We are now designing a compliance program with the goal of ensuring more robust compliance training throughout each level of our organization. In addition, OSI provides employees responsible for supply chain management and procurement with on-going opportunities to update the company’s practices with respect to ethical sourcing. OSI’s supply chain personnel participate in industry trade groups, on-line industry and academic programs as well as benchmarking practices against those of other companies in the food industry.