California Transparency in Supply Chains Act of 2010 (SB 657)

In an effort to educate consumers and eradicate slavery and human trafficking from supply chains passing through California, the California legislature enacted the California Transparency in Supply Chains Act of 2010 (SB 657).  This law requires large retail sellers or manufacturers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their supply chains.
Epson is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We will respect fundamental human rights and facilitate a fair, safe, healthy and pleasant work environment.

Epson America, Inc., its parent entity, Seiko Epson Corporation and the Epson Group companies are primarily engaged in developing, manufacturing, selling, and providing services for printing solutions, visual communications products, and wearable and industrial products.

For more information on the Epson Group companies, including annual financial statements which have statements dedicated to the subject of Epson’s global efforts related to Slavery and Human Trafficking, please visit the following link: https://global.epson.com/SR/our_people/respect.html#h2_02

In 2005, Seiko Epson Corporation established the Principles of Corporate Behavior (Corporate Social Responsibility Guidelines) which are adhered to by all companies ultimately owned by Seiko Epson Corporation, including Epson America, Inc.  In 2005 Epson also documented its policies regarding Human Rights and Labour Standards that outline our strong convictions in areas including respect for human rights, elimination of harassment, eradication of all forms of discrimination, respect for local culture and customs, prohibition of child and forced labor, and maintenance of positive labor relations.

Our policy requires us to hold our business partners to the same standards as Epson with regard to legal compliance, ethics, quality, the environment, human rights and labour conditions.

1. Verification

Epson engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery.  Under Epson's socially responsible procurement program, suppliers are asked to practice socially responsible procurement and complete an SAQ (Self- Assessment Questionnaire) to assess their own observance of the Epson Supplier Code of Conduct based upon scoring criteria for Key Performance Indicators (KPIs). Answers are verified on-site and on a continuing basis annual SAQs are provided with periodic on-site verification or third party audit.  During on-site verification, we interview workers, review documents, and tour sites to better ascertain labour and human rights risks at supplier plants.  In addition to verifications for new and existing suppliers, Epson applies a more rigorous KPI standard for key suppliers (defined as large suppliers, mission-critical parts suppliers, and sole-source suppliers).

2. Audits

Where on-site follow-up verification is not possible or feasible, Epson conducts third-party announced audits of suppliers to evaluate supplier compliance with our policies for trafficking and slavery in supply chains.  These audits are performed by independent third-party firms.  Depending on what information is discovered in the process of an audit, near-term follow-up audits may be scheduled, while follow-up audits or verifications for all vendors on a periodic basis is a fundamental component Epson’s effort to hold its business partner to the same standards as Epson holds itself to. 

3. Certification

Epson requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Epson Group Procurement Guidelines inform direct suppliers that: “Epson asks that you review and understand the spirit of these guidelines and that you agree to implement and act in accordance with them. We also ask that you effectively communicate the Epson Group Procurement Guidelines to your own suppliers”. The Guidelines also require periodic and detailed evaluation of this and other issues.

The labour standards specified in the Guidelines include freely chosen employment, child labour avoidance, working hours, wages & benefits, humane treatment, non-discrimination, and freedom of association. The Guidelines also set out an Epson Supplier Code of Conduct that aligns with the Responsible Business Alliance (RBA) Code of Conduct (which Epson became a Regular Member of in April 2019). The Code provides that suppliers are to be committed to upholding the human rights of their employees and that they treat them with dignity and respect as understood by the international community.  To enforce the Supplier Code of Conduct, Epson requires suppliers to sign a written consent form and return it to us.  Additionally, Epson executes contracts with each of its suppliers that require the supplier to comply with all laws applicable to their business.

4. Internal Accountability

Epson maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

We have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle-blowers.

Epson is committed to maintaining effective whistleblower systems. We have installed internal and external compliance hotlines and other advisory and support services for business partners to facilitate the reporting of actual or potential compliance violations, including violations of Epson Group Procurement Guidelines.

For key suppliers where verification or audits reveal issues of risk relative to compliance, Epson works with the supplier to implement a corrective action plan and follows up with further verification and/or audits to ensure achievement of improvement goals.

With respect to Epson employees, all Epson employees are made aware of and expected to comply with Epson policies, including Epson’s policies regarding Human Rights and Labour Standards that outline our strong convictions in areas including respect for human rights, elimination of harassment, eradication of all forms of discrimination, respect for local culture and customs, prohibition of child and forced labor, and maintenance of positive labor relations

5. Training

Epson provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.  We are committed to exercising high ethical standards and a social conscience, and we have declared that we will conduct our procurement activities in strict compliance with both the letter and spirit of laws and regulations in regions where we operate. Employee training is an important part of this commitment.

We invited outside instructors to conduct worker interview training for Epson employees responsible for on-site verification. This training was aimed at developing their ability to identify worker concerns and dissatisfaction within a limited amount of time. The training curriculum includes instructor lectures as well as role playing, in which the trainees learn interview techniques, procedures, and points of caution. Epson requires this training for employees who implement on-site verification to help ensure accuracy.

All employees of Seiko Epson Corporation are required to take the Introduction to Procurement (Ethics & Code of Conduct) and the Introduction to Procurement (Subcontract Act) online training courses. Employees directly involved in procurement must successfully complete procurement and compliance management training based on an in-house certification system. Renewal training is conducted every five years to ensure that employees acquire the latest information and knowledge. The scope of these initiatives is being expanded beyond SEC to the Epson Group companies as we further elevate the level of our compliance and procurement initiatives.

Further steps

In furtherance of this commitment to compliance with the California Transparency in Supply Chains Act of 2010, Epson will continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains. Additionally, Epson is committed to further improve its policies and procedures, as we refer directly to other similar legal requirements from a global standpoint (e.g., the UK’s Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, etc).