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Compliance

California Transparency in Supply Chains Act

California Transparency in Supply Chain Act of 2010 requires certain companies manufacturing or selling products in the State of California to disclose their efforts (if any) to eradicate forced labor and human trafficking from their direct supply chain.

HA-International (HAI) is committed to conducting its business in a lawful and ethical manner, and we expect the same from our suppliers. HAI’s actions to comply with the California Transparency in Supply Chains Act include the following:

Verification of Product Supply Chains
As a condition of contract, HAI requires that all direct suppliers comply with applicable laws and regulations, including labor laws.

Supplier Audits & Certification
At this time, HAI does not conduct audits of its suppliers, nor does HAI require suppliers to certify that the materials obtained from their vendors comply with the laws regarding forced labor and human trafficking in the country or countries where its suppliers do business. HAI is currently evaluating options to effectively monitor its supplier’s compliance with contract requirements.

Internal Accountability
HAI is committed to conducting its business in accordance with the highest ethical standards and expects all employees and contractors to act with integrity in performing their job functions. HAI’s Business Ethics and Conduct Policy outlines values and principles which all employees are trained to adhere to, including complying with all laws and regulations governing its business. Any employee who fails to abide by HAI’s Business Ethics and Conduct Policy will be subject to disciplinary action.

Employee Training
All HAI employees are required to acknowledge and adhere to its Business Ethics and Conduct Policy which requires that employees understand and comply with laws and regulations applicable to our business activities. Additionally, any HAI employee involved in the supply chain process is required to participate in the Department of Homeland Security web-based training, designed specifically to provide relevant information and increased awareness on the indicators of human trafficking.