Human Rights

Response to The California Transparency In Supply Chains Act of 2010

Kao Corporation, parent company to Kao USA Inc., is a participant in the United Nations Global Compact which has the goal of eradicating slave labor and human trafficking throughout the world. Kao USA Inc. supports this goal and will seek to eradicate any forced labor in our supply chain. Kao USA Inc. policies, as well as those of our parent company, require our employees to comply with all laws. We will not continue to do business with a supplier who we know to be using forced labor. Those within the company who are responsible for supply chain management are trained and aware of their responsibility to comply with all laws and Kao USA Inc. policies.

We provide the following information in response to the items of The California Transparency in Supply Chains Act of 2010:

a) 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.
EACH NEW SUPPLIER OR SUPPLIER OF A NEW MATERIAL TO KAO USA INC. MUST CERTIFY DIRECTLY TO KAO USA INC. THAT THEY AND THEIR SUPPLY CHAIN DO NOT UTILIZE HUMAN TRAFFICKING, SLAVERY OR FORCED LABOR. IN ADDITION, OUR DIRECT SUPPLIERS ARE ASKED TO CERTIFY THAT THEY AND THEIR SUPPLY CHAINS DO NOT UTILIZE HUMAN TRAFFICKING, SLAVERY OR FORCED LABOR ON A PERIODIC BASIS.
b) 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.
KAO USA INC. ROUTINELY VISITS DIRECT SUPPLIERS ON A RANDOM BASIS; HOWEVER, KAO USA INC. BELIEVES UNANNOUNCED AUDITS OF SUPPLIERS WOULD BE UNDULY DISRUPTIVE AND HAS NOT CONDUCTED UNANNOUNCED AUDITS. OUR DIRECT SUPPLIERS ARE ASKED TO CERTIFY THAT THEY AND THEIR SUPPLY CHAINS DO NOT UTILIZE HUMAN TRAFFICKING, SLAVERY OR FORCED LABOR ON A PERIODIC BASIS.
c) 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.
EACH NEW SUPPLIER OR SUPPLIER OF A NEW MATERIAL TO KAO USA INC. MUST CERTIFY DIRECTLY TO KAO USA INC. THAT THEY AND THEIR SUPPLY CHAIN DO NOT UTILIZE HUMAN TRAFFICKING, SLAVERY OR FORCED LABOR. IN ADDITION, OUR DIRECT SUPPLIERS ARE ASKED TO CERTIFY THAT THEY AND THEIR SUPPLY CHAINS DO NOT UTILIZE HUMAN TRAFFICKING, SLAVERY OR FORCED LABOR ON A PERIODIC BASIS.
d) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
IN THE EVENT KAO USA INC. BECOMES AWARE OF THE USE OF SLAVERY OR HUMAN TRAFFICKING AT ANY POINT IN OUR SUPPLY CHAIN, WE WILL IMMEDIATELY WORK TO ERADICATE THE CAUSE, WHICH MAY INCLUDE TERMINATION OF OUR RELATIONSHIP WITH THE VENDOR AS SOON AS POSSIBLE, IN ACCORDANCE WITH THE UNITED NATIONS GLOBAL COMPACT.
e) 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.
THOSE WITHIN KAO USA INC. WHO ARE RESPONSIBLE FOR SUPPLY CHAIN MANAGEMENT ARE TRAINED AND AWARE OF THEIR RESPONSIBILITY TO COMPLY WITH ALL LAWS AND KAO USA INC. POLICIES.