California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act of 2010 requires certain manufacturers and retailers to provide public disclosures on their efforts to address slavery and human trafficking in their supply chains.
Consistent with the California Transparency in Supply Chains Act, Juul Labs discloses the following efforts:
- Supplier Verification and Audits: We take reasonable actions to know our suppliers before engaging in any business with them. We may use a third party to conduct a comprehensive review of a supplier, including identifying, assessing, and managing risks related to human trafficking and slavery, if that supplier operates in a region or industry known for having a high risk of human rights or labor violations. We also conduct announced self-audits of certain suppliers to monitor and verify compliance with our contractual requirements and standards.
- Supplier Certifications and Requirements: Our suppliers certify compliance with all applicable laws, including laws addressing slavery and human trafficking, by signing contracts requiring their compliance. Suppliers also agree to follow our Third Party Compliance Manual, which sets forth standards of integrity and business conduct, including the need to uphold the human rights of workers and compliance with fair employment and labor principles.
- Internal Accountability and Training: We require all employees to adhere to Juul Labs’ Code of Conduct, which contains policies and procedures that promote compliance with applicable laws and our core values. All employees receive annual training on the Code of Conduct and are asked to acknowledge their commitment to follow it. Certain employees also receive training on our Third Party Compliance Manual, which includes human trafficking and slavery risks. Our Code of Conduct and policies are enforced through internal compliance monitoring and training. Deviations from the Code of Conduct may be reported through our anonymous hotline. Allegations of noncompliance are addressed appropriately.
