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Meeting A and S International Commodities, LLC’s obligations under the California Transparency in Supply Chains Act(SB657):

The California Transparency in Supply Chains Act of 2010 (SB 657) became effective in early 2012.This law requires large manufacturers and retailers to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The purpose of the law is to educate consumers so that they can make informed decisions and purchase?goods from companies that responsibly manage their supply chain.

A and S International Commodities, LLC’s objective is to be a good employer and a responsible and socially sensitive corporate citizen in the locations and manner in which we conduct business. In order to accomplish these objectives, A and S?International Commodities, LLC has operated a Global Business Integrity Program since the date of our incorporation in?conjunction with current Act. This Program sets forth the ethical and legal responsibilities that all A and S International?Commodities, LLC employees, contractors and suppliers are expected to uphold.

To meet our obligations under the California Transparency in Supply Chains Act (SB657), A and S International Commodities, LLC dedicated significant resources to researching and complying with the law. A and S International Commodities, LLC is hereby publicly disclosing the efforts that we routinely undertake to identify and address slavery and?human trafficking. It is our hope that these efforts will assist our customers and the public alike to make more informed?choices regarding their support of companies.

A and S International Commodities, LLC’s Mission is to serve others, and our mission of serving others goes beyond the way we treat our customers. Our corporate culture and mission are the reasons we have conducted independent third party supply chain audits of foreign factories that we use for and recognized our challenges toward establishing all required compliance with our suppliers. Our audit procedures are routinely reviewed and updated to remain current with emerging market?conditions. Our current factory audit is in full conformance with current US Department of State guidelines as well as International Organizations requirement.

These documents clearly state A and S International Commodities, LLC’s views on the ill treatment of workers, including our refusal to do business with those engaging in child labor, forced labor, discrimination, health and safety violations or the overwork of workers. A and S?International Commodities, LLC’s business principles and philosophies are founded on dignity and respect for the individual,?a strong commitment to common sense, fairness, diversity, and ethical business practices and policies.

A and S International Commodities, LLC assesses our risk of slavery and human trafficking as low for the following reasons:

  • Verification:

A and S International Commodities, LLC does not own or have financial interest in any factories, nor are we a top three customer for the majority of the factories that we use. We have a robust audit program that is designed to identify, and eliminate from our supply chain, any factories that do not meet our ethical standards, such as violations of our policy against?the use of child or forced labor. We use a continuous improvement model with factories that are being dealt with and willing to assure required improvements.

A and S International Commodities, LLC works with industry organizations and experts to benchmark our program and address evolving issues. As a result we continuously update our program and develop tools to identify cases of forced or child?labor, physical or sexual abuse and harassment.

  • Auditing:

An independent third party inspectorate firm audits all facilities producing direct import merchandise for A and S International Commodities, LLC at least annually. We primarily use announced audits, but unannounced and surveillance audits are sometimes used, depending on the circumstances. We chose third party audit companies with accredited and international reputation of having experienced auditors who are experts in identifying false records, conducting worker interviews and otherwise detecting violations of our ethical standards.

The findings of the audit may result in the relationship with the supplier being severed and no product accepted, such as in the case of a facility that uses child or forced labor. In other cases, a factory may be suspended for a period for failing to make?required implementations and improvements in a timely manner.

  • Certification:

Suppliers must sign the A and S International Commodities, LLC Supplier Agreement and agree to abide by our Code of Conduct as well as our Corporate Sociability Standards. Those standards require that the products provided to A and S?International Commodities, LLC will be manufactured only in accordance with our social accountability standards and all US regulatory, including but not limited to:
-No child labor, all workers must be 16 years of age or older if required by law,
-No forced or involuntary labor.

The vendor is required by the Terms and Conditions on the Purchase Order to warrant that the product is not produced or packaged with the use of child or forced labor, or in violation of any other human rights.

  • Accountability:

All employees and suppliers are governed by the A and S International Commodities, LLC Code of Business Conduct and Ethics. Signing the Code of Business Conduct and Ethics is one of the requirements for employment at A & S Int’l. Violations of the Code can result in discipline or loss of employment. Supplier or factory allegations are investigated, and A and S International Commodities, LLC reserves the right to terminate the relationship with any supplier or factory that violates our code.

A and S International Commodities, LLC maintains a vendor manual for suppliers which calls out that we have Zero Tolerance for the use of Child Labor (workers must be at least sixteen years of age) or Forced labor (all types of forced labor?to include prison, bonded, and indentured.) We reserve the right to visit at any time all facilities used in the production of goods for the corporation.

  • Training:

A and S International Commodities, LLC conducts training for employees with supply chain responsibilities, to increase their?understanding of how to recognize signs of ethical violations in the supply chain. Members of our compliance department?review any identified factory issues with management and the merchants to keep them updated on how to interpret audit results and auditor comments.

In addition, we visit and work closely with our overseas alliances to ensure a consistent?message and complete understanding of our requirements. We educate about the risks in certain countries and product?categories, using the US Department of Labor ‘s List of Goods Produced by Child Labor or Forced Labor.

For full transcript of California Senate Bill, Please click here.