The California Attorney General has kicked off a campaign to ensure that companies are complying with their obligations under the state’s Transparency in Supply Chains Act of 2010. On April 1, 2015, the AG’s office sent letters to companies it believes may be subject to the Act seeking reports on compliance with the Act’s disclosure obligations within 30 days. While self-reporting on compliance is voluntary, we expect that the AG will focus enforcement investigations on non-responders and those companies that report that they are noncompliant.

Under the Act, retailers or manufacturers doing business in California with annual worldwide gross receipts that exceed $100,000,000 must disclose what efforts they take to eradicate slavery and human trafficking from their supply chains. This disclosure must be accessible from an easily understood link on the business website’s homepage.