Last February, I wrote about the California Transparency in Supply Chains Act of 2010. The law has now taken effect and I’m now seeing many companies making the disclosures required by the Act. For example, PVH Corp., which describes itself as “one of the world’s largest apparel companies, owns and markets the iconic Calvin Klein and Tommy Hilfiger brands”, makes this disclosure on its website.

One interesting aspect of the new law is its effect on suppliers down the food chain. Lately, I’ve been fielding questions from companies that aren’t subject to the Act’s disclosure requirement. Why? These companies are suppliers to companies that are subject to the Act. Subject companies are requesting/insisting that their suppliers make certifications with respect to human trafficking and slavery issues. Whether a supplier must comply with a request may depend on the terms of its agreement with the manufacturer or retailer. In at least one case, I’ve seen a retailer assert that compliance is mandated because suppliers have agreed to comply with the retailer’s Code of Business Conduct.