California Transparency In Supply Chains Act - Allegro Coffee

California Transparency In Supply Chains Act Disclosure

Allegro Coffee Company’s Disclosure under the California Transparency in Supply Chain Act
of 2010

Effective January 1, 2012, the California Transparency in Supply Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts to eradicate slavery and human trafficking from its direct supply chain. The following is Allegro Coffee Company’s required disclosure under the Act:

1. Risk Assessments: Allegro Coffee Company performs a preliminary risk assessment of suppliers of its 365 Products and Allegro products purchased at the national/global level, to determine the level of risk associated with slavery and human trafficking in their supply chain. This risk assessment is conducted via a questionnaire.

2. Auditing: Allegro Coffee Company relies upon third party certifiers for all 365 Products. Allegro Coffee Company verifications prioritize laborer conditions and rights. The verification process will also include best practices on food safety and environmental criteria.

3. Certification Requirements: Allegro Coffee Company requires all of its direct suppliers to certify in writing that they and the producers of goods and material used by them in products they sell to Allegro Coffee Company comply with Allegro Coffee Company’s standards with respect to slavery, human trafficking and bonded labor prior to doing business with Allegro Coffee Company. Allegro Coffee Company verifies these standards with annual audits. Allegro Coffee Company standards include a requirement to comply with the laws regarding slavery, human trafficking and bonded labor in the countries in which suppliers are doing business.

4. Internal Accountability: Allegro Coffee Company is committed to the ethical and socially responsible conduct in the workplace. All of its employees and contractors must adhere to its Code of Business Conduct, which requires compliance with all laws in the countries in which suppliers are doing business including laws addressing slavery, human trafficking and bonded labor. Violations of the Code of Business Conduct by employees may result in disciplinary action up to discharge. Violations by contractors may result in their dismissal. We do not have a formal policy in-place outlining the steps a contractor must follow to resolve any documented failures/shortcomings. We do not have a policy that specifically protects team members or vendors who act as whistle blowers.

5. Procurement Training: Allegro Coffee Company’s annual training teaches its team members who are responsible for supply chain management, the principles and practices underlying its standards relating to slavery, human trafficking and bonded labor and provides education on how to identify and respond to supply chain issues such as slavery, human trafficking and bonded labor.