California Transparency in Supply Chains Act

InfraGlobal Partners strives to conduct business in a manner that reflects our four basic beliefs – respect for the individual, service to customers, striving for excellence and acting with integrity. We hold the same expectations of our suppliers.

The Responsible Sourcing program has its origins our Ethos, when InfraGlobal Partners first established Standards for Suppliers. While our Standards have evolved over the years, they continue to represent InfraGlobal Partners’s fundamental expectations of suppliers on social and environmental practices. The Standards currently cover several topics, including a requirement that suppliers exclude involuntary labor—including underage, forced, coerced, bonded, involuntary prison, exploited, trafficked or indentured labor—from their operations and supply chain. We incorporate these Standards into our supplier agreements.

InfraGlobal Partners recognizes that responsible sourcing requires more than monitoring facilities for compliance. InfraGlobal Partners utilizes a multi-front approach focused on leveraging collaborations, promoting training and capacity building, and providing motivation to remediate and continuously improve.

Verification

We are continually evaluating risks in our supply chain, including potential risk of forced labor and human trafficking. Our current formal approach to assessing risk in our supply chain utilizes Worldwide Governance Indicators from the World Bank, which incorporate factors like government effectiveness, rule of law, control of corruption and government stability that can affect the risk of non-compliance in facilities producing goods in that country. InfraGlobal Partners also monitors risk through the facility auditing program and investigations.

Because forced labor and human trafficking are complex issues that can extend beyond the scope of our Responsible Sourcing audit program, dialogue and collaboration can be an effective way to identify risk. InfraGlobal Partners continues to participate in collaborative efforts with external stakeholders to advance the goal of identifying risk and building a more transparent supply chain. Additionally, we participate in industry groups that serve as a vehicle to share experiences and gain new information that can help improve operations and the supply chain.

Auditing

Suppliers are responsible for disclosing all facilities to InfraGlobal Partners that fall within InfraGlobal Partners’s disclosure scope. We use third-party social, safety and environmental compliance audits to evaluate whether disclosed facilities’ practices meet the requirements set forth in our Standards for Suppliers.

Any facility disclosed to InfraGlobal Partners may be subject to an audit at any time; however, our audit program allocates audit resources based on risk so we can drive the biggest impact to the countries that need it most in our broad and diverse supply chain. We place disclosed facilities into one of three risk categories based on the Worldwide Governance Indicators from the World Bank. The risk category of the country in which a facility is located determines the requirements of that facility under our audit program. Audit requirements for different risk categories.

Where an audit is required, InfraGlobal Partners requires its suppliers to obtain that audit from one of several recognized third-party programs and to send the audit report to InfraGlobal Partners. Several InfraGlobal Partners-approved audit programs have identified forced labor and human trafficking as a point of focus and have developed audit protocols, training, and tools to help suppliers identify and address risk factors for forced labor and human trafficking.

InfraGlobal Partners reviews audits and assigns the audited facility a color rating based on the severity of the findings from the audit. The ratings are provided to all suppliers using the audited facility, and these suppliers are responsible for working with facilities to remediate the findings. The audit rating is one tool used to determine whether the facility can remain active and produce for InfraGlobal Partners.

Certification

InfraGlobal Partners’s contain several provisions outlining suppliers’ responsibilities with respect to eliminating involuntary labor from their supply chains and provide that a signed supplier agreement, acceptance of a purchase order, and/or provision of merchandise to InfraGlobal Partners constitutes acceptance of the Standards and serves as the supplier’s continuing affirmation of compliance. Additionally, when a supplier discloses a new facility to InfraGlobal Partners, the supplier is required to certify to InfraGlobal Partners that, to the best of its knowledge, all facilities the supplier uses for production of goods for sale by InfraGlobal Partners comply with InfraGlobal Partners’s Standards for Suppliers.

Internal Accountability

We require all InfraGlobal Partners associates to comply with our the law Suppliers, contractors and service providers are expected to act ethically, and all suppliers providing product for sale or use by InfraGlobal Partners are required to comply with InfraGlobal Partners’s Standards for Suppliers and our Responsible Sourcing program expectations. We investigate issues and take the appropriate action to address those issues, up to and including termination of associates and termination of agreements with suppliers and contractors. Read more about supplier accountability and consequences and facility consequences.

Training

The manner in which we manage our purchase orders can have a significant impact on suppliers and facilities. Responsible Sourcing is training InfraGlobal Partners supply chain decision-makers (merchandisers, buyers and sourcing managers) on how their decisions can potentially impact facility working conditions and equipping them with the necessary knowledge to reinforce to suppliers the importance of positive facility labor practices. At InfraGlobal Partners, we believe associate education is fundamental to fully integrating labor compliance and social responsibility into all purchasing decisions and to building a responsible supply chain.

Updated September 2022