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California Transparency in Supply Chains Act Disclosure


The California Transparency in Supply Chains Act (the “Act”) requires large retailers and manufacturers doing business in California to disclose on their websites their efforts to eradicate slavery and human trafficking from their direct supply chain for tangible goods offered for sale. CPO Commerce, LLC (“CPO”) provides the following disclosures under the Act.


Verification. CPO is committed to conducting its business in a lawful and ethical manner and expects it product vendors to make the same commitment. CPO expects its product vendors to comply with a Supplier Code of Ethics (ESND Supplier Code of Ethics), which includes a requirement that product vendors comply with applicable laws, including those prohibiting slavery and human trafficking. At this time, CPO does not use a third party to verify the risks of human trafficking in its supply chain.


Audit. At this time CPO does not conduct audits of manufacturing facilities of the vendors from whom CPO purchases products.


Certification. CPO includes a statement in its form of vendor operating agreement that CPO expects the vendor to comply with a Supplier Code of Ethics (link above). For vendors who do not sign CPO’s form of vendor operating agreement, CPO otherwise communicates its expectation regarding compliance with the Supplier Code of Ethics to the vendor.


Internal Accountability. CPO maintains internal accountability standards and procedures as part of the Essendant Code of Business Conduct (ESND Code of Business Conduct). The ESND Code of Business Conduct requires employees to comply with applicable laws and sets forth procedures for handling situations where an employee or supplier has failed to meet company standards. Every CPO employee is required to abide by the ESND Code of Business Conduct and must sign an annual acknowledgment stating they have read it.


Training. At this time, CPO does not provide employees or contractors with specific training on human trafficking and slavery.