The California Transparency in Supply Chains Act of 2010 (Calif. Civil Code § 1714.43) requires manufacturers and retailers to provide information on their efforts to address slavery and human trafficking risk in their supply chains so consumers can make informed choices about products they buy and companies they support.

Swisher (together with its subsidiaries and affiliates, “Swisher”) strives to maintain a culture of compliance with all applicable laws, rules and regulations, and the highest standards of ethics and business conduct, including with respect to human trafficking, slavery and forced labor of any kind, including child and prison labor.  Swisher expects its suppliers to do the same.

Swisher is a member of GAP Connections, a 501(c)(5), nonprofit agricultural membership organization in the U.S. which provides leadership for the adoption of agricultural standards and practices to produce a quality tobacco crop while protecting, sustaining or enhancing the environment, ensuring the safety and rights of farm laborers, and recognizing those producers who are committed to a higher standard. 

For tobacco and other materials that Swisher sources from abroad, Swisher goes directly to the source, and makes local trips into the warehouses to make sure there is no forced or child labor.

Swisher will not knowingly do business with any supplier that supports, condones or is associated with slavery, human trafficking or forced labor.

Swisher informally monitors its supply chain and assesses all potential suppliers in an effort to detect any issues.  In most instances Swisher does not conduct any formal audits, however one of our affiliates does have an independent, third party monitor in place to inspect and audit its overseas manufacturers’ facilities.   The audit is conducted by the independent monitor, who reviews manufacturing practices at the facilities for a variety of concerns, including forced and child labor, during an announced audit. 

The majority of Swisher’s material suppliers are U.S.-based companies, and none of Swisher’s factory visits and other interactions with these suppliers have caused concerns about the use of an illegal labor force.

If Swisher becomes aware that a supplier has a higher level of risk in this regard, Swisher will take all appropriate action, which may include auditing the supplier’s facilities.

In addition to requiring suppliers with whom it contracts to attest to compliance with all laws, Swisher has recently required certain direct suppliers to provide representations regarding compliance with the minimum age of employment requirements prescribed by the International Labor Organization’s (ILO) Minimum Age Convention (No. 138), 1973, in addition to providing representations that they do not and will not employ forced labor or impose similar working conditions.  Swisher is evaluating expanding certification requirements to all direct suppliers.

Other than the efforts described above, Swisher does not currently have specific standards or additional procedures in place that pertain to slavery and human trafficking. Swisher is in the process of setting up a program to conduct formal training regarding issues of slavery and human trafficking for management and employees having direct responsibility for supply chain management.