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CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT


Spencer’s supports the right of all individuals to be free from slavery in the workplace. We abhor the practice of human trafficking and slavery and applaud efforts being made globally to eliminate this practice.

VERIFICATION
Spencer’s is in the process of implementing a program that will assess the risk of human trafficking and slavery posed by our direct source vendors.  An independent third party verifier will administer the program.
AUDITS
Spencer’s utilizes an independent, third party auditor to confirm that our international suppliers comply with all employment laws.  The audits are announced.  Spencer’s does not conduct audits of our suppliers here in the United States.    
CERTIFICATION
Spencer’s requires all of its suppliers to be compliant with all local and national laws governing slavery and human trafficking in the countries in which they do business. By accepting a purchase order or contract, every supplier certifies that it conducts business in compliance with local and national laws related to employment, and its failure to do so is a breach of the contract.  
INTERNAL ACCOUNTABILITY
Spencer’s has adopted a policy for our employees and contractors that sets forth our expectations and standards with regard to the fair treatment of our employees. Spencer’s policy specifically prohibits forced labor. Spencer’s provides training on these standards for our employees and management, and we provide a confidential hotline for employees to report concerns related to their fair treatment and other employment related issues.  We prohibit retaliation against anyone who in good faith reports a possible violation of our policy.
TRAINING
All of our employees who have direct responsibility for international supply chain management receive internal and external training on slavery and human trafficking issues.  Our international buying team receives this training in connection with every international buying trip, which typically occur several times each year.
Beginning in 2015, Spencer’s will also offer human trafficking and slavery training to its suppliers