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California Transparency in Supply Chains Act Disclosure
To the extent, if at all, that Nexans USA Inc. or any of its subsidiaries* (“Nexans USA”) are subject to the requirements of the California Transparency in Supply Chains Act of 2010 (the “Act”), Nexans USA provides this disclosure statement concerning its efforts to eradicate slavery and human trafficking from its direct supply chain. Nexans USA is part of the Nexans S.A. Group of Companies (“Nexans”).
Nexans integrates Corporate Social Responsibility (CSR) in its strategy and respects the highest standards of business ethics and business conduct which are summarized in its Code of Ethics & Business Conduct. By adhering to the UN Global Compact, Nexans confirms its commitment to respect its fundamental principles in the areas of human rights, labor standards, the environment, fight against corruption and marks its determination of deploying improvement action plan to increase its performance in the field of sustainable development. Nexans has created a Supplier CSR Charter which attests to Nexans’ determination of promoting and sharing the application of CSR principles with its suppliers, with whom Nexans pursues to build a business relationship based on honesty, trust and mutual interest.
To the extent practical, Nexans USA requests its suppliers to sign the Supplier CSR Charter and to take part in the Nexans CSR approach by committing themselves in a continuous improvement approach towards the principles listed in the Supplier CSR Charter. The Supplier CSR Charter establishes the principles that suppliers shall adhere to in their activities and at sites worldwide. These principles include the following principles with respect to Human Rights & Labour Standards:
Forced & Child Labour
Nexans suppliers commit to respect the international human rights laws, eliminate all forms of illegal, forced or compulsory labour and reject child labour.
Diversity & Fairness
Nexans suppliers respect equal opportunities rights and seek to provide their employees with a work environment free of discrimination or harassment of any kind whatsoever. Nexans suppliers’ employees are treated with fairness and dignity.
Nexans suppliers respect the right of associations. Suppliers respect the right of employees to form or join the unions and workers’ organizations of their choice and to participate in collective negotiations.
Working Hours & Training
Nexans suppliers comply with local legislation regarding working hours and minimum wages and strive to provide to its employees development programs and trainings.
Health & Safety
Nexans suppliers deploy necessary resources to ensure the health and safety of their employees in their workplace, through continuous improvement, according to applicable legislation and health and safety management system.
It is a requirement of the Supplier CSR Charter that selected suppliers shall adhere to the principles stated in the Supplier CSR Charter and comply with international, national and local laws and regulations, which are applicable to their activities, sites worldwide and countries in which they operate. Respect of the Supplier CSR Charter will be considered in the continuing commercial relationship between Nexans USA and its suppliers. The Supplier CSR Charter encourages suppliers to join the UN Global Compact and to promote the principles in the Supplier CSR Charter to its own suppliers and own sphere of influence. The Supplier CSR Charter is part of the documentation that is typically included in the Nexans USA RFP and contract signing process. When a Supplier signs the Supplier CSR Charter, a signed copy of the Supplier CSR Charter is kept on file. While the majority of Nexans USA’s direct suppliers certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business, Nexans USA does not request or obtain a certification from all Suppliers. However, it is usually a requirement of the commercial contract with each supplier that they conduct their activities in compliance with all applicable laws.
Audits and Verification
Nexans USA does not presently engage in verification of its product supply chain to evaluate and address risks of human trafficking and slavery, nor does it audit its suppliers with respect to compliance with company standards for trafficking and slavery in supply chains.
Accountability Standards and Training
In the future, Nexans USA may further evaluate the ways that it may reduce human trafficking in its direct supply chain. Because accountability standards and a training program have not been developed specific to human trafficking and slavery, this may include developing internal accountability standards and procedures for determining whether employees or contractors are complying with company standards regarding slavery and human trafficking and providing training to those who have direct responsibility for supply chain management regarding the mitigation of the risk of slavery and human trafficking in Nexans USA’s supply chain.
*The subsidiaries of Nexans USA Inc. include AmerCable Incorporated, Nexans High Voltage USA Inc., Nexans Energy USA Inc., The Valley Group, Inc., Berk-Tek LLC and Nexans Aerospace USA LLC.
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