NASSCO complies with the California Transparency in Supply Chains Act (Cal. Civ. Code § 1714.43) (“the Act”) by doing the following.
- Verification. In connection with NASSCO’s supplier qualification list (QSL) process, NASSCO requires all prospective suppliers to complete a questionnaire and provide information about their business practices so that NASSCO can assess the supplier’s compliance in general. NASSCO only does business with suppliers who successfully complete the QSL process. The verification process is performed by NASSCO and not performed by a third party.
- Audits. NASSCO reserves the right to audit a supplier’s compliance with NASSCO’s terms and conditions and the QSL process. Such audits would only be conducted if there was reason to believe that a supplier was not in compliance with NASSCO’s standards against trafficking and slavery in supply chains.
- Certifications. NASSCO’s supply chain management process was recently updated to obtain a signed certification from each supplier before the supplier can be added to NASSCO’s QSL. The certification states that the supplier represents and warrants that it is compliance with the Act and federal human trafficking regulations aimed to stop human trafficking. Additionally, NASSCO’s purchase orders also bear a standard pre-printed note that states “By accepting this PO, Seller certifies that it is in compliance with FAR 52.222-50, DFARS 252.222-7007 and the California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code § 1714.43), and that Seller does not engage in forced labor, slavery, or human trafficking.”
- Accountability. General Dynamics’ Standards of Business Ethics and Conduct (“the Blue Book”) governs NASSCO’s ethics and business standards. The Code of Ethics includes, among other things, that our employees will comply with applicable laws and regulations. Human trafficking and slavery are illegal, and constitute a violation of the Blue Book by our employees and suppliers. Such a violation would result in a disciplinary action against the employee. Any supplier found to be engaging in slavery or human trafficking will be terminated and removed from the QSL.
- Training. NASSCO provides training to its Supply Chain Representatives on the Act and federal human trafficking regulations.