California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act of 2010 (SB 657) seeks to eliminate slavery and human trafficking from product supply chains. This act requires companies doing business in California to disclose their efforts to make sure that their supply chains are free from practices that could be construed as slavery and human trafficking.
FCA US LLC has zero-tolerance for both forced labor and child labor. We expect our suppliers to recognize and obey laws that require them to treat their workers fairly, with dignity and respect, and to provide a healthy and safe work environment.
FCA US uses several tools in our assessment of where there may be risk of forced or compulsory labor. We require all direct material suppliers to complete a self-assessment in which they must indicate whether they have policies consistent with the FCA Guidelines for Suppliers, whether they train their employees in these principles and whether these principles are cascaded to their suppliers. These results are reflected on supplier performance scorecards.
The next level of our supplier assessment takes place through on-site supplier audits, which can be announced or unannounced and are conducted by either internal Supplier Quality engineers or external auditors. We determine which supplier locations through the evaluation of supplier self-assessments and other risk indicator criteria.
The General Terms & Conditions of FCA US purchase orders contain language specifically forbidding the use of forced, child or compulsory labor. They also state that we may request suppliers to certify in writing their compliance (and that of their subcontractors) that they are not utilizing slave, prisoner, child, or any other form of forced or involuntary labor in connection with the supply of goods or provision of service.
While we do not currently require explicit certification of suppliers that the materials they provide comply with local laws regarding slavery and human trafficking, this is being evaluated as part of our review of Purchasing Terms and Conditions.
To help Purchasing and Supplier Quality personnel to recognize their role in ensuring responsible working conditions, we provide training on the issues surrounding global working conditions, as well as how to identify potential risk scenarios that could indicate problems.
FCA US works with NGO’s (Non-Governmental Organizations) and multi-stakeholder groups to develop and maintain processes and tools to identify potential risk and to help in the reduction of human rights violations in the supply chain.
We continue to work with the Automotive Industry Action Group (AIAG) and other automakers and suppliers in developing our industry’s “Global Working Conditions Guidance Statements.” This industry guidance document addresses seven areas of responsible working conditions, including the prohibition of any form of forced or compulsory labor.
FCA US employees from Purchasing, Supplier Quality and Sustainability are engaged in the AIAG Corporate Responsibility Steering Committee, the Global Working Conditions Corporate Engagement Training Workgroup, and the Global Working Conditions Oversight Committee. We have collaborated to develop and provide no-cost, on-line training covering global working conditions, which is available to all suppliers directly through AIAG at this website.
Partnering with other automakers and AIAG, we also provide mandatory training to suppliers in high-risk areas at no cost. Suppliers who attend the training are required to cascade the training materials and messaging to their suppliers, delivering these expectations to a broader audience than we could do directly. The training covers multiple aspects of human rights concerns, focusing primarily on forced, compulsory and child labor as well as environmental topics and business ethics.
We continue to develop and provide additional training and tools which will be available at no cost to suppliers through our eSupplier Connect Portal, the required communication channel for all FCA US suppliers and through our course offerings during Supplier Training Week, which is conducted several times each year. In addition, anyone who has identified potential problems can contact our Sustainability Group at firstname.lastname@example.org.