California Transparency Act

CENVEO'S INFORMATION REGARDING CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

As a leading player in the industry, we fully recognize our responsibility to operate within the spirit and letter of the law and to maintain high ethical standards wherever we conduct business. Cenveo does not condone or tolerate efforts or activities to achieve results through illegal or unethical dealings anywhere in the world.

Cenveo's suppliers know that Cenveo is concerned not only with results, but also with how those results are achieved. We expect all of our suppliers to conduct their businesses with the same high standards. We will actively seek business relationships with suppliers who share our values and promote the application of these high standards among those with whom they do business.

The State of California Transparency in Supply Chains Act of 2010 (the "Act") requires that manufacturers and retailers disclose their efforts to eradicate slavery and human trafficking from the supply chain. The steps below describe Cenveo's efforts to comply with the Act (the numbered bolded topics are directly from the Act):

 

  1. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

    Cenveo is currently developing a protocol to evaluate our suppliers and identify high-risk suppliers on a number of parameters including known risks and country location. Forced and child labor is included in the known-risk category, and we will use the U.S. Department of Labor's Bureau of International Labor Affairs ("ILAB") "List of Goods and Countries" as an aid in the evaluations.

  2. Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

    Cenveo is currently evaluating a procedure to audit suppliers to ensure compliance with Company standards for trafficking and slavery in supply chains.

  3. Requires 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.

    As a standard, Cenveo seeks to include in its purchasing contracts language mandating that suppliers be in full compliance with all applicable governmental, legal, regulatory, and professional requirements. Suppliers will also be required to comply with Cenveo's forthcoming prohibition on employing children, prison labor, indentured labor, bonded labor, and using corporal punishment or other forms of mental and physical coercion as a form of discipline.

    Cenveo has a number of print facilities that have Chain of Custody certification under the Forest Stewardship Council™(“FSC®"), which monitors the legal status of products in the supply chain and the conditions of workers. We will continue to aggressively pursue certification of additional facilities.

  4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

    All Cenveo employees are required to comply with the Code of Business Conduct and Ethics. Cenveo is currently revising the Code of Business Conduct and Ethics to state specifically that Cenveo does not condone the unlawful use of child, prison, indentured or bonded labor, or using corporal punishment or other forms of mental and physical coercion as a form of discipline.

    All new Cenveo employees must acknowledge receipt of and their responsibility to read and abide by the Code of Business Conduct and Ethics. As well, in the event of any substantive changes to the Code of Business Conduct and Ethics, each employee must acknowledge receipt of and each one's responsibility to read and abide by the Code of Business Conduct and Ethics. Furthermore, each year select Cenveo employees must acknowledge receipt of and each one's responsibility to read and abide by the Code of Business Conduct and Ethics. Our company investigates all allegations of non-compliance. If allegations are substantiated they are addressed as appropriate.

  5. Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

    Cenveo has and will continue to provide employees and management with specific training related to identifying and reporting human trafficking and slavery for those employees and contractors linked directly to supply chain management. Cenveo expects all employees to comply with all applicable laws and regulations in the conduct of our business activities. This extends to laws regarding slavery or human trafficking in the countries in which we do business.

    Please send an email to info@cenveo.com if you have any questions or need additional information.