Grace Farms Foods Anti-Slavery Statement and California Transparency in Supply Chains Act of 2010 (SB 657) Introduction

“Human Trafficking is a crime against humanity. It involves an act of recruiting, transporting, transferring, harbouring or receiving a person through a use of force, coercion or other means, for the purpose of exploiting them.” – United Nations Office on Drugs and Crime

Human trafficking is a form of forced labor, and the second most prevalent form of illegal trade in the world, just after the illicit drug trade and equal to the sale of illegal arms. Sometimes referred to as modern day slavery, it is also the fastest growing illegal business in the world.¹ International Labor Organization (ILO) data shows that there are at least 12.3 million victims of forced labor worldwide, 2.4 million of which result from human trafficking. Men are affected, but women and children are particularly vulnerable.²

Human trafficking in any industry is a result of poverty and a lack of education, government action and political will. It’s often thought of as a problem in the illegal sex trade, but human trafficking can be found in garment factories, fabric and trim mills, and even on farms in the supply chain. Factories that use third-party labor brokers or unmonitored subcontractors are particularly susceptible. Even in the United States, where foreign migrant workers may seek employment through third-party brokers, factories sometimes employ human trafficking victims.

Grace Farms Foods prohibits any form of forced labor, including slavery and human trafficking in our supply chain. This is a zero-tolerance issue. If this grave concern was ever to be found in our supply chain, the factory would be subject to our disciplinary policy found in our Supplier Code of Conduct. In all cases factories must immediately remediate the issue, and face possible termination of business.

The California law only requires us to disclose our due diligence in these areas, however we’ve added additional information to our disclosure statement about the steps we’ve taken to ensure there is no child labor in our supply chain. We did this to further enhance transparency in our statement and prepare for pending federal legislation similar to SB 657.  As a new, small business Grace Farms Foods is not subject to adhering to the California Transparency in Supply Chains Act, but it is our goal to meet and exceed these standards from the beginning.

We fully support the efforts of Grace Farms Foundation and a growing number of anti-slavery activist groups, NGOs and our state and federal government to shed light on human trafficking, slavery and child labor in the supply chain. They’ve created helpful tools that brands and suppliers can use to prevent, identify and remediate these issues. We are hopeful that these serious human rights concerns will continue to receive more attention and analysis going forward.

The steps we’ve taken so far are part of our mission to fulfill a core area of impact of our Built on Purpose program: Freedom For All.

Disclosure of Grace Farms Foods pursuant to SB657.

The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, that the retail seller or manufacturer does each of the following:

(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.

(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.

(3) Requires a direct supplier to certify that materials incorporated into a product comply with slavery and human trafficking laws in the country or countries in which that supplier is doing business.

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

(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

As a new, small business starting during the COVID-19 pandemic, Grace Farms Foods is committed to using its wherewithal to eliminate any reasonable doubt that forced labor exists in its supply chain.  Grace Farms Foods has implemented the following practices:

First-Party Audits:

• Grace Farms Foods conducts interviews with all potential suppliers to assess the risk of forced labor in the supplier's supply chain
• Grace Farms Foods requires all suppliers of ingredients and packaging to complete a Supplier Questionnaire and agree to our Supplier Code of Conduct.
• We have identified forced labor and similar human rights abuses as a Zero-Tolerance infraction.  Any indication of forced labor will result in immediate termination of agreement with the supplier.

Third-Party Audits:

• When applicable and available, Grace Farms Foods seeks to source ingredients that have been sourced to third-party standards such as Fairtrade Certified and Fair Trade Certified by Fair Trade USA.
• When applicable and available, Grace Farms Foods seeks to source paper and packaging products that is FSC Certified.

Staff and Supplier Education:

• All Grace Farms Foods employees are given an onboarding training to understand the risks of forced labor in our supply chain and the tools used to identify any reasonable doubt that forced labor exists in our supply chain.
• All Grace Farms Foods employees are required to attend at least three events hosted by Grace Farms Foundation; one of which must be hosted by the Justice Initiative.
• All suppliers are invited to collaborate or request educational materials from Grace Farms Foods and Grace Farms Foundation related to forced labor and human trafficking.