The California Transparency in Supply Chains Act of 2010 (the “Act”) requires large manufacturers who do business in the State of California and have gross worldwide sales of over $100 Million Dollars to be transparent about their efforts to eradicate Slavery and Human Trafficking in their supply Chain.  Within the meaning of the Act, Slavery and Human Trafficking concern the practice of utilizing forced or compulsory labor in any work or service that is exacted from any person under the menace of any penalty, and for which that person has not offered himself or herself voluntarily.  In accordance with the Act, this statement articulates our policies and practices around recognizing and preventing human trafficking and slavery in the global supply chain.

Act of Captain Eco

As part of our Health & Sustainability Standards at Captains Inc., we are committed to supporting social justice and human rights – it’s simply a part of our company DNA to wish good health and happiness to everyone.

In addition to our corporate commitment to transparency, the California Transparency in Supply Chains Act of 2010 (SB 657) requires retailers and manufacturers of a certain size doing business in California to provide consumers with information regarding a manufacturer’s efforts to eradicate slavery and human trafficking from its supply chain.

As part of our commitment to human rights, here at The Captains Inc. we:

• Make inquiries of and audit our vendors to assess direct and indirect risks to its supply chain, including its labor practices.

• Share with and expect our vendors to sign the Captains Inc. Vendor Manual. The manual addresses our expectations of our vendors, which includes sharing our commitment to having a safe and ethical supply chain free of human trafficking and forced, involuntary or child labor.
• Internally maintain accountability standards and procedures for our employees and contractors who fail to meet company standards, including our hiring practices.
• Train managers and employees who have direct responsibility for supply chain management to be aware of issues that can impact the supply chain such as the risk of human trafficking and slavery.

While we’ve always believed in fair labor and human rights, we appreciate that California has a law that requires us to be transparent about our policies. We hope to educate consumers so they can purchase goods from companies that take active steps to help end slavery and human trafficking. And although it’s not required in every state, we hope you’ll inquire about it with any company you decide to buy from. Every purchase you make has an impact – and together, we can make it better!

What does Slavery and Human Trafficking Mean in the Twenty-First Century?

Slavery and Human Trafficking concern the practice of utilizing forced or compulsory labor in any work or service that is exacted from any person under the menace of any penalty, and for which that person has not offered himself or herself voluntarily.  Providing wages or other compensation to a worker does not necessarily indicate that the labor is not forced or compulsory.

By right, labor should be freely given and employees should be free to leave in accordance with established rules.  While forced or compulsory labor can present itself in many forms, in our global manufacturing business, examples of conduct which may amount to forced or compulsory labor are:

• Child labor in particularly abusive conditions where the child has no choice about whether to work
• Physical abduction or kidnapping

• Sale of a person into the ownership of another
• Physical confinement in the work location (in prison or in private detention)
• The work or service of prisoners if they are hired to or placed at the disposal of private individuals, companies or associations involuntarily and without supervision of public authorities
• Requiring the indefinite lodging of deposits, financial, or personal documents as condition to employment
• Destroying, confiscating or denying access to an employee’s identity documents, such as passports or drivers’ licenses

• Charging employees (as opposed to employers) recruitment fees as a condition for securing employment
• Physical or psychological (including sexual) violence as a means of keeping someone in forced labor (direct or as a threat against worker, family, or close associates)
• Full or partial restrictions on freedom of movement
• Withholding and non-payment of wages (linked to manipulated debt payments, exploitation, and other forms of extortion)
• Deprivation of food, shelter or other necessities

• Deception or false promises about terms and types of work
• Induced indebtedness (by falsification of accounts, charging inflated prices, reduced value of goods or services produced, excessive interest charges, etc.), and
• Threats to denounce workers in an irregular situation to the authorities

Associates, contractors, and suppliers aware of any such conduct should report it to HR or the Legal Department. Consistent with company policy, Captains Inc. forbids retaliation against any employee who reports or assists in an investigation of unlawful conduct, including Slavery and Human Trafficking. Employees who believe they have been the subject of retaliation should follow the company’s internal complaint mechanism for reporting retaliation.