The following are Lutron’s response to each key point described in the The California Transparency in Supply Chains Act of 2010.
The extent that Lutron:
I. 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.
Lutron’s purchasing personnel routinely conduct on-site inspections of certain strategic suppliers. Suppliers are graded on several factors, including observed human rights issues and adherence to Lutron’s Supplier Code of Conduct (available at: /supplier-terms-conditions). Verification is conducted by employees of Lutron and its affiliated companies.
II. 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.
Currently, Lutron performs on-site and off-site audits of suppliers for multiple factors, including adherence to Lutron’s Standard Terms and Conditions of Purchase and Lutron’s Supplier Code of Conduct (see references below). Frequency and scope of audit is based on past performance reviews and supplier risk. Generally, these audits are announced and conducted by Lutron’s supply chain personnel. Additionally, Lutron sources select products from suppliers that participate in third party verification programs and/or have adopted the Electronic Industry Citizenship Coalition’s (EICC) Code of Conduct or are participants in related programs such as the Conflict-Free Smelter (CFS) assessment program. See: http://www.eicc.info/
III. 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.
Below is an example of Lutron’s Standard Terms and Conditions of Purchase that are incorporated into supply agreements or purchase orders with direct suppliers.
Seller warrants that all goods provided under a Purchase Order have been produced and all services performed in compliance with applicable federal, state and local laws, ordinances, codes, rules, regulations or standards, including without limitation, the Fair Labor Standards Act, and those pertaining to the manufacture, labeling, invoicing and sale of such goods or services, environmental protection, immigration, employment and occupational safety and health.
(Lutron’s Standard Terms and Conditions of Purchase available at: /supplier-terms-conditions)
IV. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Lutron employees are required to strictly observe all applicable laws and regulatory requirements. Lutron requires its suppliers to adhere to its Supplier Code of Conduct which provides:
- Child Labor
Lutron will not engage in or support the use of child labor. Suppliers are expected to comply with all applicable local child labor laws and employ only workers who meet the applicable minimum legal age requirement for their location.
- Minimum Wages
Suppliers shall provide wages for regular and overtime work and benefits that meet or exceed legal requirements.
- Forced Labor
Suppliers shall not use any forced, prison or indentured labor. Lutron will not engage in or support the use of forced or involuntary labor and as a result, Lutron will not purchase material or services from a supplier utilizing forced or involuntary labor.
- Discrimination
Lutron supports diversity and equal opportunity in employment. Unlawful discrimination in the workplace is not tolerated. Suppliers are expected to comply with all applicable local laws concerning discrimination in hiring and employment practices.
(The full text of Lutron’s Supplier Code of Conduct is available at: /supplier-terms-conditions)
V. 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.
Lutron provides training to employees responsible for supply chain management on how to identify and respond to supply chain issues, such as human trafficking and slavery; all suppliers are expected to fully comply with Lutron’s Supplier Code of Conduct.
Revised: 12/31/2011
Lutron Document: 167322
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