Transparency in Supply Chains Act Disclosure
This disclosure is provided pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657), which is effective January 1, 2012.
General Position in Support of the Eradication of Forced Labor, Slavery, Human Trafficking, and Child Labor Violations
Blue Coat Systems, Inc. (“Blue Coat”) supports efforts to eradicate forced labor, slavery, human trafficking and child labor violations (collectively, “Prohibited Conduct”), and believes that companies should take reasonable actions to manage their product supply chains to promote this goal. Blue Coat believes that the particular actions taken and the time period within which any particular action should be taken, may vary and may change from time to time. Blue Coat currently is implementing certain processes to promote social responsibility by material suppliers within its direct supply chain for products (“Suppliers”).
In compliance with California Civil Code Section 1714.43 (the California Transparency in Supply Chains Act of 2010) Blue Coat hereby makes the following disclosures:
- Verification: Blue Coat does not have a formal program for proactive verification that its Suppliers are not engaging in Prohibited Conduct, but has commenced a program to increase the awareness and sensitivity to these issues, both internally and with respect to its Suppliers. This program includes training for its employees involved in selecting, qualifying and managing Suppliers to assist those employees in identifying when a supplier may be at risk of engaging in Prohibited Conduct. In the event Blue Coat is made aware that a particular Supplier may be engaging in Prohibited Conduct, it will undertake such investigation and take such action as it deems reasonable and proper under the circumstances.
- Auditing: Blue Coat does not have a formal program to proactively conduct audits of its Suppliers with respect to Prohibited Conduct or otherwise. Blue Coat’s contracts with its Suppliers typically include a representation by the Supplier that it will comply with all applicable laws. In the event Blue Coat is made aware that a particular Supplier may be engaging in Prohibited Conduct, it will undertake such investigation and take such action as it deems reasonable and proper under the circumstances.
- Certification. Blue Coat’s contracts with its Suppliers typically include a representation by the Supplier that it will comply with all applicable laws. In addition, Blue Coat intends to seek to amend its existing agreements Suppliers to include a certification that materials incorporated into any product provided to Blue Coat comply with the laws regarding slavery and human trafficking of the country or countries in which the Supplier is conducting business.
- Internal Accountability. In the event an employee or Supplier engages in or fails to address Prohibited Conduct, the consequences for non-compliance will depend on the nature, circumstances and context of the violation. Consequences can include any or all of the following: termination of an existing contract with the Supplier; non-renewal of an existing contract with the Supplier; increased reporting or other requirements on the Supplier; more stringent verification or audit obligations; more stringent cure or performance obligations; a claim for breach and contract damages; requiring additional education; remediation; disciplinary action or employment termination (if an employee); or such other remedies available at law, in equity or by agreement as Blue Coat deems appropriate under the particular circumstances and context in which such non-compliance arose.
- Training. Blue Coat has provided training to its current employees and managers who have direct responsibility for supply chain management. The current training addresses identifying the risks of Prohibited Conduct, elements to watch for when selecting or qualifying a prospective Supplier, and evaluating the performance of an existing Supplier.
Scope of this Disclosure; Limitations
The disclosures contained on this link are made as to the current actual knowledge of Blue Coat on the Effective Date. Except as required by applicable law, Blue Coat does not undertake to update this information.
If you have further questions or concerns about Blue Coat’s supply chain management and compliance with the California Transparency in Supply Chains Act of 2010, or if you have any information regarding the activities of any Blue Coat supplier in contravention of California or US laws against slavery, human trafficking, forced labor or child labor, please email Blue Coat at email@example.com. For more information about this site, please email us at firstname.lastname@example.org.
Effective Date: December 29, 2011.