California Transparency in Supply Chains Act of 2010
The California Transparency in Supply Chains Act of 2010 (the “Act”), effective January 1, 2012, requires Gentex to disclose its efforts to eradicate human trafficking and slavery within its supply chain.
Gentex is committed to conducting its business in an ethical manner. Gentex does not knowingly acquire any raw materials, intermediate goods or finished products which are made with forced labor.
Gentex’s Code of Conduct states that, at a minimum, all Gentex employees are expected to comply with all applicable laws and regulations. The Code of Conduct states that all employees must conduct themselves in an ethical manner. Gentex intends to amend its Code of Conduct to specifically address laws and ethical issues relating to human trafficking and slavery within its supply chain.
The majority of Gentex’s business comes from contracts (either prime or subcontract) with the United States government. In such contracts, Gentex is governed by the Federal Acquisition Regulation (“FAR”) 52-222.50 Combating Trafficking in Human Persons. Gentex flows down such FAR requirements to its suppliers and requires the FAR clause to be flowed down through the supply chain to lower-tier suppliers. Furthermore, the government contracting market is highly regulated, and Gentex believes this highly regulated environment also aids in eliminating human trafficking within the supply chain.
On an annual basis, Gentex requires most of its suppliers to certify that they are in compliance with all applicable laws and regulations. Gentex intends to ensure all suppliers sign an annual certification certifying they are in compliance with the Act and with FAR 52-222.50 in future certifications. This certification process is not undertaken by a third party.
Currently, unless a specific issue is raised with respect to a Supplier, Gentex does not undertake audits of suppliers to evaluate supplier compliance with the Code of Conduct in respect to human trafficking and slavery laws. Gentex does not currently provide training specifically regarding human trafficking and slavery issues.