California Transparency in Supply Chains Act Disclosure
Lavazza North America Inc (“LNA”) supports the goals of the California Transparency in Supply Chains Act (the “Act”). LNA strives to be a responsible corporate global citizen with regard to human rights and labor practices and demands the same legal compliance and ethical conduct from its business partners. LNA is committed to ensuring that its supply chain complies with the policies and business principles established by LNA’s parent company Lavazza S.p.A. (together with LNA, “Lavazza” “we” or “us”).
The Act requires that certain businesses disclose their efforts in addressing modern slavery and human trafficking that might be present in their supply chains.
LNA’s actions concerning the Act’s goals include the following:
1. Product Supply Chains/Suppliers
A. Lavazza has adopted, and requires its suppliers to adopt, a Supplier Code of Conduct (the “Code of Conduct”) that prohibits suppliers from using or benefiting from forced labor and requires suppliers to comply with applicable laws on working hours, wages and benefits.
B. The Code of Conduct emphasizes adherence to (a) the UN Global Compact’s Ten Principles that are derived from the Universal Declaration of Human Rights, including, in particular, Principle 1 and Principle 2 thereof, (b) the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, (c) the Rio Declaration on Environment and Development, (d) the Convention on the Rights of the Child, and (e) the United Nations Convention Against Corruption.
2. Supplier Audits
A. The Code of Conduct reserves to Lavazza the right to audit its suppliers’ compliance with the Code of Conduct. Lavazza reserves the right to demand corrective measures or terminate an agreement with suppliers who do not comply with the Code of Conduct.
B. Lavazza’s Internal Audit Department, which reports directly to Lavazza S.p.A.’s Board of Directors, is responsible for implementing an effective auditing system throughout Lavazza worldwide.
C. Lavazza S.p.A. has established a model of organization, management and control (the “Model”), which is an internal controls compliance program mandated by the Italian Legislative Decree No. 231/2001 (the “Decree”). The employees covered by the Model must inform Lavazza S.p.A.’s Supervisory Board of any conduct that would result in a violation of the provisions of the Decree, the Model and/or Lavazza’s Code of Ethics, as well as any specific offenses. To ensure compliance, Lavazza has established a dedicated whistleblower channel for employees to report to the Supervisory Board. The Supervisory Board ensures that anyone submitting a report is protected against any form of retaliation, discrimination or detriment.
3. Supplier Compliance
A. The Code of Conduct requires suppliers to adhere to all applicable labor, health and safety, and environmental laws.
B. Lavazza is committed to adhering to internationally recognized human rights, international and national labor laws and environmental principles. We engage in a continuous dialogue with our suppliers to share the ethical values characterizing our way of doing business along the entire supply chain and to ensure that no slavery or human rights violation of any kind occurs along our supply chain.
C. Based on these principles and those contained in the Code of Conduct, Lavazza has begun a program that requires our suppliers to certify that no Lavazza coffee comes from sources connected to modern slavery or human trafficking. For example, with regard to coffee beans sourced from Brazil, Lavazza requires that its suppliers certify that they do not source from plantations that are identified on Danwatch’s “Transparency List on Contemporary Slavery in Brazil” or that they know may violate laws regarding human rights.
4. The Code of Conduct
A. Since Lavazza S.p.A. was founded in 1895, Lavazza’s business practices have been governed by integrity, honesty, fair dealing and full compliance with all applicable laws. Lavazza’s Code of Ethics requires its employees worldwide to prescribe to these same values and principles.
5. Employee Training
A. Lavazza’s employees are required to acknowledge that they have received and read Lavazza’s Code of Ethics.
B. Lavazza provides training to its employees, with specific emphasis on its supply chain staff, to understand how modern slavery and human trafficking can affect our supply chains and our business. We also require our business partners to provide training to their staff and suppliers and providers.
C. Lavazza provides further training worldwide in good corporate social responsibility, focusing in particular on anti- corruption and anti-bribery.