California Supply Chain Disclosure
The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in the State of California to disclose efforts to eradicate slavery and human trafficking from its direct supply chain. The company does not use and will never use, and will endeavour not to conduct business with persons or entities that use, forced, indentured, involuntary or child labor or engage in human trafficking. As set out in the Company’s Code of Business Conduct and Ethics, the Company is committed to conducting its business following the highest standards of fairness, honesty and integrity and in compliance with all legal and regulatory requirements. In order to sell transit buses to federally-funded transit agencies in the United States, the Company must manufacture buses that comply with Buy America regulations (49 CFR 661). The majority of components purchased by the Company are manufactured in the United States and represent a low risk that forced, indentured or involuntary labor was used in their manufacture. Consequently, the Company has a very limited number of suppliers located outside the United States and Canada. All production suppliers are subject to an on-site verification audit of their quality and management systems to ensure performance to the Company’s specifications and requirements. This supplier verification audit includes a review of the supplier’s safety management and human resources policies. In the event the Company determines that a supplier uses forced, indentured or involuntary labor practices, the Company will move to develop alternate sources of supply and will terminate its relationship with the offending supplier. The Company is currently reviewing its supply purchasing procedures and processes in order to develop more robust standards for supplier labor practices.