The California Transparency in Supply Chains Act requires that covered manufacturers and retailers disclose their efforts in the below categories to prevent forced labor and human trafficking within their direct supply chains. Publishers Clearing House is dedicated to conducting its operations throughout the world on universal principles of ethical business practice and the recognition of the rights of all workers. We expect our product supply and sourcing partners to adhere to the same high standards in the conduct of their business operations, and we utilize such criteria to evaluate our relationships with our suppliers.
Verification and Risk Evaluation
Our business partners must verify under our Code of Conduct that they will not work with or source products or materials from business partners who utilize prison, indentured or other forced labor in any stage of the manufacture of products or their component parts or materials.
Monitoring our supply chain remains a dynamic process, and we work continuously to adapt to the changing global environment in which we operate. We conduct periodic review and risk assessments of the vendors and suppliers in our supply chain to identify areas of potential risk and to develop appropriate steps to address any identified risk.
Publishers Clearing House participates in industry updates, seminars, and other informational gatherings from practitioners in this area to identify relevant issues or trends. Such efforts allow us to further improve transparency in the supply chain and better identify areas of risk.
Our business partners may subcontract work on our products only to parties whose policies and practices meet or exceed the high standards of ethical business practices set forth in this Code of Conduct. It is the responsibility of our business partners to ensure that any subcontractor meets or exceeds those standards.
Auditing
It is the responsibility of our business partners to monitor compliance with our Code of Conduct by their employees, business partners and suppliers, and to ensure that partners at all levels are held accountable for compliance with these standards in their own businesses and in sourcing products and materials from their own suppliers. This may include their own efforts in conducting announced or unannounced audits within the supply chain.
Certification
Business partners in our Supply Chain are required to sign our Code of Conduct and to comply with accompanying restrictions and requirements in their business with PCH. Among other provisions, our Code of Conduct expressly requires our suppliers to agree that:
- They will not work with or source products or materials from business partners who utilize prison, indentured or other forced labor in any stage of the manufacture of products or their component parts or materials.
- They will ensure that their workers are provided a safe and healthy work environment and are not subject to unsanitary or hazardous conditions.
- Regardless of local legal or cultural requirements or allowances, they will not employ workers under the age of sixteen.
Internal Accountability
PCH employees who have responsibility or oversight for sourcing products and working with vendors within our supply chain are required to conduct their operations with the recognition of the need to prevent forced labor and human trafficking within the supply chains. All such employees will have read and be familiar with the provisions of our Code of Conduct.
Allegations or findings of actions in violations of the Code of Conduct will be investigated and appropriate responsive action taken. If there is credible evidence that one of our suppliers, or one of their contractors, is violating the provisions of our Code of Conduct we may cancel existing orders, suspend, or terminate our relationship with such supplier.
Training
PCH employees who have oversight or responsibility for sourcing products and working with vendors within our supply chain are required to attend training sessions to build awareness of how human trafficking and forced labor may reveal itself in supply chains. The training is designed to support PCH's efforts to prevent forced labor and human trafficking within our supply chain.