What is the California Transparency Act?

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. This law is designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Standards for Contractors, Suppliers and Licensees

PING is committed to being the unquestioned leader in innovation, design, service and quality while providing an enjoyable environment for employees that allows them to fulfill their potential. PING expects the highest performance from not only itself, but also from its Contractors, Suppliers and Licensees (CSLs) and their suppliers and contractors. PING seeks to work with those CSLs who progressively raise employee standard of living through improved wage systems, benefits, welfare programs and other services, which enhance quality of life, employee safety and the environment in which we live and work.

PING has commenced the establishment of a Code of Conduct and Responsible Sourcing program for CSLs and their downstream suppliers. Staff members have conducted initial onsite evaluations and reviews of current suppliers for adherence to the PING Code of Conduct. Historically, PING’s overall supply chain management program has included: supplier completion of site evaluation documents; site visits by PING representatives, and supplier evaluation on numerous levels including health, safety, environmental and labor issues.

PING’s Code of Conduct establishes expectations for our CSLs to foster respect for people, promote social responsibility, create a healthy and safe workplace, encourage environmental stewardship, achieve product excellence and advance market leadership. PING will work cooperatively with its CSLs to ensure that this Code of Conduct and associated Management Standards are fully implemented. Any CSL that wishes to maintain and/or establish a business relationship with PING shall agree to be bound by the PING Code of Conduct. Failure to meet the minimum standards for our CSLs and their suppliers can result in loss of contracts or other appropriate repercussions.

Slavery and human trafficking can take many forms, including forced labor and child labor. PING’s Code of Conduct requires our supply chain to meet social and environmental responsibility requirements. PING has undertaken efforts to ensure and verify the absence of forced labor and child labor in our supply chain.

These efforts include:

• Supplier assessments - PING performs assessments of potential suppliers using a risk-based approach. This approach includes preliminary risk assessments and supplier assessment questionnaires.
• Supplier audits - Risk-based audits are conducted and include a review of Code of Conduct requirements which include forced labor and child labor prohibitions. Various types of announced audits are conducted under this program, including onsite audits attended by PING personnel. In addition third-party Fair Labor Association unannounced on-site audits may be performed at applicable facilities. Following audits, suppliers are required to produce corrective action plans, which PING reviews and approves. The corrective action plans outline how a supplier will resolve issues uncovered in audits. PING will not tolerate the presence of forced and child labor. If any zero-tolerance items are uncovered in audits, we require suppliers to rectify the problem and PING will confirm resolution of the issue.
• Supplier agreements - PING has purchasing agreements and/or purchase order terms and conditions in place with all our direct suppliers requiring them to comply with international standards and applicable laws and regulations.