Supply Chain Responsibility: California SB 657

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will require large manufacturers and retailers that sell goods in California to make certain disclosures regarding their efforts to address slavery and human trafficking. The act is intended to ensure that retail manufacturers and sellers are disclosing their efforts to eradicate slavery and human trafficking from their supply chains.

Bel-Air Lighting is committed to observing high ethical standards in the conduct of its business. We are committed to the goals of SB 657 and are committed to compliance with all laws and regulations governing efforts to address slavery and human trafficking. In establishing and maintaining relationships with our suppliers, we ask them to be committed to the same high ethical standards, and that they are not linked to activities that would be considered abusive or exploitive, including human trafficking and slavery.

Bel-Air Lighting does engage in verification of our product supply chain to ensure compliance with laws governing slavery and human trafficking. These verifications do not currently include a certification regarding the materials used in manufacture by each supplier. Verification is conducted by a third party.

In addition, our customers possess audit rights to our factories and conduct audits. Audits are performed annually by leading third party audit providers, such as Bureau Vertas, Intertek, and SGS. The audits are semi-announced. Suppliers are informed that an audit is forthcoming but are not told the actual day.

Bel-Air Lighting maintains the highest ethical standards in its business dealings.

As part of its internal accountability system to ensure compliance with all laws and regulations, Bel Air Lighting can take action upon discovery of violations, including requesting a prompt redress of alleged violations, and corrective actions, as well as the potential for termination of the supplier relationship in the event of violations or failure to adequately remedy violations.

Bel-Ari Lighting's current employee training program does not include training on how to minimize the potential risk of slavery and human trafficking in the supply chain.