California Supply Chain Disclosure

The California Transparency in Supply Chains Act requires retailers and manufacturers that do business in California to publicly disclose their efforts to eliminate slavery and human trafficking from their supply chains.

Deringer-Ney, Inc. (DNI) is committed to fair employment practices and to compliance with employment laws in the United States and other countries where we manufacture or source products sold in our supply chain. It is expected that our suppliers also conduct themselves in this manner. Our Vendor Code of Ethics requires that our suppliers conform to the following requirements:

Legal Compliance

Deringer-Ney Inc. (DNI) Vendors shall conduct their employment practices in full compliance with all applicable laws and regulations stipulated by the legal system of their country.   Suppliers must also adhere to all applicable trade laws as well as all export, re-export, and import requirements while conducting business. Vendors are expected to comply with the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding Conflict Materials.

Basic Human Rights

The infliction of any physical abuse or corporal punishment is strictly prohibited. Vendors must provide a sound working environment, never discriminate against, or resort to unfair employment practices based on gender, color, race or religion.  Working conditions must be safe, the wages and working hours must comply with applicable laws.  DNI requires use of only volunteer labor; the use of forced labor in the form of indentured, bonded, or prison labor is not acceptable.

Prohibition of Child Labor

Vendors must comply with child labor laws and never employ children below the minimum age stipulations. Vendors must adhere to the regulations stated by the International Labor Organization

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Deringer-Ney has implemented a California Supply Chain compliance questionnaire as part of its Supplier Information Documentation for certain of its direct suppliers. The suppliers are asked, among other questions, whether they are in compliance with applicable slavery and human trafficking laws in the countries in which they operate. DNI assesses the disclosures made by the suppliers. The evaluations are not conducted by a third party. DNI will conduct periodic audits of certain suppliers to evaluate compliance with company standards for trafficking and slavery in the supply chain. DNI expects compliance with all applicable federal, state and local laws by suppliers with whom DNI has a contractual relationship. Compliance with such laws includes compliance with laws forbidding human trafficking and slavery.

Deringer-Ney is implementing a Code of Business Conduct and Ethics to educate and hold employees responsible for conducting DNI’s business in compliance with applicable laws and in accordance with the Company’s standards of ethical conduct. The Code of Conduct requires that DNI complies with Human Rights and employment laws in every country in which it operates.  Employees who violate the Code of Conduct are subject to appropriate discipline, which may include termination of employment. 
 

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