California Transparency in Supply Chain Act Disclosure Information

McCain Foods USA, Inc. and its subsidiaries (McCain) are in the retail and foodservice seller/manufacturer as that term is defined in the California Transparency in Supply Chains Act of 2010 (the “Act”), California Civil Code Section 1714.43(a)(1). Accordingly, pursuant to the requirements in the Act, McCain makes the following disclosures:

1.  McCain’s Code of Conduct specifically prohibits human trafficking and slavery in its work place and its product supply chains. Although McCain does not engage in third-party verification to evaluate and address risks, all complaints filed with the McCain Code of Conduct Hotline, hosted by a third party provider, are promptly and thoroughly investigated and handled as appropriate
2. McCain requires its suppliers and contract manufacturers to adhere to the McCain Supplier Code of Conduct with respect to all aspects of business dealings. The McCain Supplier Code of Conduct, which suppliers are contractually required to follow, prohibits suppliers from engaging in or benefiting from any form of human trafficking. This includes the recruitment, transportation, transfer, harboring or receipt of persons, by means of threat or use of force or other forms of coercion, abduction, fraud, deception or abuse of power or a position of vulnerability.  Giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation is also strictly prohibited.  McCain’s suppliers are obligated to maintain necessary documentation to demonstrate their compliance with the Supplier Code of Conduct, and McCain reserves the right to audit their operations to ensure compliance. Currently, audits are not regularly performed, nor are they conducted by an independent party.
3. McCain’s Supplier Code of Conduct requires all direct suppliers that provide materials incorporated into the product to act in accordance with all applicable federal, state, and local laws and regulations, as well as international laws, when applicable.
4. All employees and contractors are expected to follow McCain’s Code of Conduct, which sets forth the requirement that specifically prohibits human trafficking and slavery and requires that all employees are treated fairly and in accordance with all federal, state and local laws. Any employees and/or contractors who are found to be in violation of McCain’s Code of Conduct are dealt with appropriately.
5. McCain provides annual training to all California-based company employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery and mitigating risks within supply chains.