Cumberland Packing Corp. Information Regarding California Transparency In Supply Chains Act of 2010
Cumberland Packing Corp. (“Cumberland”) is committed to a zero tolerance policy on human
trafficking and forced labor. The State of California Transparency in Supply Chains Act of
2010 requires certain retail sellers and manufacturers to post a disclosure on their web site
regarding their efforts to combat human trafficking and forced labor in their supply chains.
Cumberland is committed to working with suppliers who share the same values and respect for
human rights as Cumberland. Accordingly, Cumberland has established the following guidelines
when dealing with potential suppliers.
1. Risk Assessments - Cumberland performs preliminary risk assessments for slavery and human
trafficking of potential suppliers according to a risk based approach based on any suspected
or known risks, and country location. As discussed below, each Cumberland supplier will be
visited and inspected by Cumberland and/or its representatives to confirm such preliminary risk
2. Auditing - Each existing and proposed Cumberland supplier has been inspected by
Cumberland employees and/or independent representatives. If Cumberland should identify any
suppliers at high risk for slavery or human trafficking, such suppliers would be subject to an
on-site audit to determine if such suppliers are meeting the ethical and quality standards set by
Cumberland. Cumberland will determine at the time of such audit whether the audit will be
conducted by Cumberland, or its designee or an independent third party.
3. Certification - Cumberland is in the process of reviewing and establishing a certification
procedure to either (i) require direct suppliers to certify that they are complying with all laws
and regulations related to slavery and human trafficking, or (ii) require such compliance by the
Supplier contractually as agreements are entered into or renewed.
4. Internal Accountability - All employees and contractors of Cumberland are expected to
comply with all laws, including laws addressing slavery and human trafficking. Failure to
adhere to the applicable laws may result in disciplinary action up to and including discharge and
termination by Cumberland.
5. Procurement Training - Cumberland encourages employees who are responsible for supply
chain management to obtain training on all aspects of supply chain management including on
how to mitigate risks of slavery and human trafficking within the supply chain. Such training
may include seminars, webinars, or internal presentations.