Anti-Slavery & Human Trafficking Policy

Purpose, Scope, Transparency as well as Laws

Purpose and Scope

Stauff Corporation and its affiliated companies (collectively “Stauff”) are committed to conducting international business in accordance with all applicable Anti-Slavery and Human Trafficking Laws in the United States and other countries where Stauff operates.  These laws, including the California Transparency in Supply Chains Act of 2010, prohibit human slavery and human trafficking, as well as most forms of forced, coerced, and compulsory labor.

Stauff maintains this Anti-Slavery and Human Trafficking Policy (“Policy”) to promote compliance with these laws.  This Policy covers all Stauff employees, officers, directors, agents, consultants, and any other persons acting on behalf of any entity owned or controlled by Stauff (“Stauff Personnel”).  Violations of Anti-Slavery and Human Trafficking laws can result in severe consequences, including civil penalties, criminal penalties, and possible incarceration. Accordingly, violations of this Policy will result in disciplinary action, up to and including termination. 

Anti-Slavery Laws

Slavery can take various forms, including forced labor, coerced labor, compulsory labor, or child labor.  “Owning” a person is not necessary so long as involuntary servitude exists.  According to the United Nations,

  • “human trafficking” is “the process by which a person is recruited, transported, transferred, harbored, or received through a use of force, coercion, or other means, for the purpose of exploiting them.”  
  • “slavery” is “the status or condition of a person over whom any or all the powers attaching to the right of ownership are exercised,” or “the status or condition of a person over whom control is exercised to the extend that the person is treated like property.” 

This policy also covers forced labor (all work or service, not voluntarily performed, that is obtained from an individual under threat of force or penalty) and harmful child labor (the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development).

Against this backdrop, Stauff Personnel must never knowingly engage in any of the following activities:

  • Employing any form of slavery, human trafficking, forced labor, coerced labor, compulsory labor, or child labor at any Stauff facilities;
  • Encouraging or facilitating any form of slavery, human trafficking. forced labor, coerced labor, compulsory labor, or child labor by third parties; or
  • Sourcing, purchasing, or importing goods and services from third parties engaged in any form of slavery, human trafficking forced labor, coerced labor, compulsory labor, or child labor

Stauff has zero tolerance for any form of slavery or human trafficking.  Accordingly, Stauff Personnel who observe (or have good reason to suspect) any of the prohibited activities identified above  must immediately suspend the underlying activities or transaction(s) and contact the Legal Department for further guidance.  Knowingly failing to do so constitutes a violation of this Policy and may result in disciplinary action.

Supply Chain Transparency

Stauff expects its third party suppliers and vendors to comply with the requirements set forth in this Policy and any applicable Anti-Slavery and Human Trafficking laws.  However, currently, we do not undertake efforts to verify our supply chain to evaluate risks for human trafficking and slavery, nor do we require our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business.  We reserve the right to modify our practices and adopt such processes in the future.

Recordkeeping Requirements

Stauff reserves the right to audit its suppliers’ compliance with these policies.  If the supplier is presenting a serious risk, the audit may be unannounced.  Although Stauff regularly monitors its suppliers for a variety of reasons, an audit is typically not performed to determine compliance with the prohibitions against slavery and human trafficking, nor are these audits typically conducted by third parties.  Nevertheless, Stauff will promptly and thoroughly investigate any claim or indication that a supplier is engaging in human trafficking or slave labor.  

Stauff will not continue to purchase goods or services from any supplier of which it is made aware to be engaging in human trafficking or using slave labor without proper cure or remedy of such practices.

Reporting Violations

Stauff Personnel that observe any potential or actual violation(s) of this Policy, or the underlying Anti-Slavery & Human Trafficking laws, must immediately contact the Legal Department. All calls are anonymous.  Stauff does not permit any form of retaliation for the good faith reporting of suspected violations of the law or company policies.