Services Supporting Transparency in Supply Chains Act (SB 657) Disclosure Compliance

The Warnath Group offers a suite of services to help companies with the Transparency in Supply Chains Act (SB 657) human trafficking disclosure requirements. SB657 requires retail and manufacturing companies with more than $100 million annual worldwide revenue and doing business in California – regardless of where they are headquartered – to disclose their efforts to maintain a supply chain free of human trafficking and slavery in statements on their websites.

Our package of program options – training, consulting, research and assessment by lawyers and leading experts tailored specially to SB657  — helps company management have confidence in the strength of these disclosures specific to human trafficking and slavery. As required by the Act, companies began to make their initial disclosures in 2012.  Commentators have noted a wide disparity in the quality of the content of these disclosures. Going forward, we can help companies improve their SB657 disclosures as well as reduce potential underlying risks posed by subcontractors and supplier actions that may not fully conform with a company’s standards and procedures and international, federal, and state legal standards associated with those disclosures. Our services include:

SB657 Certificate Training Programs for Employees

The Warnath Group has set the quality standard for customized training on human trafficking worldwide. The professionalism and high quality of this training is available to companies to satisfy underlying objectives of Transparency in Supply Chain Act disclosure. We offer a range of training programs, including certificate courses for employees, from general introductory training to customized advanced training for your individual departments, offices and business sector on human trafficking and slavery. Our courses are available for small groups or all of your employees. Courses can be presented in multi-country offices with simultaneous interpretation. We also offer continuing legal education for your in-house counsel and specialty courses for your corporate leaders.  Our trainings can be provided on-site or online (webinars and podcasts).

We utilize training techniques with an extensive track record for being engaging, interactive and effective for participants. The content of our trainings are adapted to be most relevant and effective for your company. Topics include modules for understanding the nature of the problem and effective best practices that are company and industry- specific and take into account applicable international and national law as well as relevant country and industry contexts. If your company has a training program for your employees and suppliers already on related topics, we can work with you to refine and strengthen it by integrating new material on human trafficking into your existing training.

With WG’s trainings, your company’s SB657 disclosure will be able to highlight that your employees have received training, documented by quantifiable metrics, that are based upon customized educational programs on human trafficking that are recognized as representing the highest quality available.

Research and Analysis of Human Trafficking Laws of Countries in which Your Company Does Business

SB657 requires companies to disclose whether they require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. The Warnath Group has analyzed and consulted on the variations and nuances of human trafficking laws in countries around the world.  Our research and analysis of these laws in the country or countries in which your corporation does business will support your company’s compliance process as well as more precisely gauging future business risk. We also work with companies and their suppliers to provide needed training and expert guidance to suppliers so that the certification of direct suppliers underlying company disclosures is informed by a heightened understanding of applicable human trafficking law and policy.

Review Company Standards and Procedures to Encompass Human Trafficking

SB657 requires companies to disclose whether they possess internal accountability standards and procedures for employees and contractors for failing to comply with company standards regarding slavery and human trafficking. We review corporate policies, standards and procedures on these issues and work with company management to provide applicable revisions to internal Codes of Conduct, standard operating procedures, internal accountability standards and procedures.


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