CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (the "Act") went into effect in the State of California. This law aims to increase the amount of information made available by manufacturers and retailers regarding their efforts to address the issue of slavery and human trafficking.

As a leading importer and manufacturer in the United States, Pompeian fully complies with the California Transparency in Supply Chains Act of 2010 and is committed to ensuring that our products are obtained and produced through ethical and fair labor conditions. We work directly with farmers across the World, to source the highest quality raw materials, and place the utmost importance on verifying that our products are processed in facilities that comply with existing laws. In our processing facilities (foreign and domestic), employees are provided with fair wages, regular working hours, and a clean working environment.

We work tirelessly to provided verification and traceability of every product that we produce. It is our commitment and obligation to provide the highest level of traceability and transparency to our consumer, partners, and employees. With that, we seek to ensure quality, safety, and the highest level of employment standards are maintained throughout our supply chain. 

Verification
Pompeian evaluates its suppliers and manufacturers by conducting random audits; including site visits and required documentation regarding all manufacturers’ practices and processes. Through our code of conduct, we ensure that our suppliers commit to nonnegotiable labor standards such as, “No forced labor, whether prison, bonded, indentured or otherwise and no engagement or support in trafficking of human beings.” We do not use third party verification services.

Supplier Audits 
Suppliers and manufacturers are validated by Pompeian through a compliance audit and/or onsite visit. Pompeian evaluates its suppliers and manufacturers by conducting both random and announced audits. Some audits occur at initial engagement, other ones when visits are performed to the different countries (Spain, Argentina, Chile, etc.) The audit is a process that helps our suppliers identify areas within their operations that can be improved, and serves to make them aware of the laws of the United States in terms of food safety and fair labor conditions. 

In the event that Pompeian becomes aware of any actions or conditions not in compliance with Pompeian’s Supplier Code, we reserve the right to demand corrective measures and/or terminate an agreement with any supplier or manufacturer. 

Certification 
Pompeian supports and complies with laws and regulations prohibiting forced, compulsory, and child labor. We require our suppliers and manufacturers to keep records about every worker, including proof of age and contracts if necessary. In addition, we keep accurate records of hours and wages worked for all Pompeian employees. Our team evaluates suppliers through the completion of a compliance package that covers a supplier’s policies, procedures and record keeping.

Additionally, business activities of suppliers and manufacturers must conform to applicable national and local legal requirements, customs, and published industry standards pertaining to employment and manufacturing. If statutory requirements and published industry standards conflict, suppliers must, at a minimum, be in compliance with the one which, by law, takes precedence.

Internal Accountability
Pompeian maintains and enforces internal accountability procedures to address employee compliance with company standards. Upon being hired, all Pompeian employees receive training in compliance with the law and the company’s Employee Code of Conduct. Annual refresher training sessions are given, and disciplinary action is taken on Employees that do violate the code of conduct. Our business practices are governed by integrity, honesty, and full compliance with all applicable laws.

Training
Every Pompeian employee is trained on the company’s Code of Conduct and such training is part of the good manufacturing practices and processes applied by the company. The training includes information and annual refreshers on the issues of human trafficking and slavery. Pompeian maintains training sessions within the company in accordance with each department’s needs and areas of expertise.

Pompeian will continue to evolve and adapt its practices toward providing the highest levels of training and awareness surrounding employee safety, as well as providing fair/lawful labor conditions.