California Transparency in Supply Chains Act Disclosure
The California Transparency in Supply Chains Act of 2010
requires certain retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. Lehigh Hanson and its affiliated companies doing business in California, as well as all other companies making up the HeidelbergCement Group, are committed to complying with international social and environmental standards. These standards are set forth in the HeidelbergCement Group Sustainability Report
and HeidelbergCement’s Supplier Code of Conduct
Almost all of the products sold by Lehigh Hanson companies in North America are produced or manufactured using raw materials and products obtained locally from the company itself, a Lehigh Hanson affiliate, or a third party supplier. Taking into account company policies, social norms, and federal, state or provincial, and local laws, it is highly unlikely that slavery or human trafficking are implicated in these local supply chains. The verification of these product supply chains is conducted within the Lehigh Hanson organization.
For the handful of raw materials obtained from foreign suppliers, such as gypsum, iron ore, and bauxite used in manufacturing portland cement, the number of suppliers is small – no more than a dozen or so – and the suppliers can be evaluated for compliance with company standards on an individual basis without the need for independent, unannounced audits. At times, portland cement is itself imported from foreign affiliates or a small number of suppliers. Again, the number of suppliers is small and they can be evaluated for compliance on an individual basis.
In any event, suppliers are bound, directly or indirectly, by the requirements of HeidelbergCement’s Supplier Code of Conduct
. These requirements are implemented by certifications from direct suppliers and/or contractual provisions in purchase orders or agreements with direct suppliers, all of whom are required to exercise diligence in verifying that the Supplier Code of Conduct is adhered to by their own suppliers.
Employees and managers are subject to discipline, including termination, for failure to abide by Lehigh Hanson policies, including failure to observe company standards regarding slavery and human trafficking. Contractors and suppliers are subject to having their contracts with Lehigh Hanson terminated should they violate the Supplier Code of Conduct.
The relatively few company employees and managers with direct responsibility for supply chain management are in Lehigh Hanson’s purchasing department. All of these employees and managers receive regular training in the Lehigh Hanson Code of Business Conduct
. Supplemental training on human trafficking and slavery and mitigating risks within the supply chains of products is offered as part of regular meetings of the purchasing department.