To whom it may concern,

Clifford Chance Business & Human Rights Global Virtual Internship have
thoroughly analysed your questions and concerns regarding the California
Transparency in Supply Chains Act ("CTSCA").

In order to be covered by the Act, a company must:

 Have annual worldwide gross receipts exceeding $100 million;

 Be identified as a retailer or manufacturer on the company’s California
tax returns; and
 Be doing business in California.

And from the information, which was provided;

your company is covered by the Act.

Further requirements for the CTSCA to apply to a company:

1. To what extent the company engages in verification of supply

chains to evaluate and address risks of human trafficking and
slavery. (If the verification is not performed by a third party, the
disclosure must specify as such).
2. To what extent the company audits suppliers to verify supplier
compliance with company standards for trafficking and slavery in
supply chains. (If such audits are not unannounced or independent,
the disclosure must specify as such).
3. To what extent the company requires direct suppliers to certify that
materials incorporated into the product comply with the slavery and
trafficking laws of the countries where they do business.
 4. To what extent the company maintains internal accountability
standards and procedures for employees or contractors failing to
meet company standards regarding slavery and trafficking.
5. To what extent the company provides employees and management
who have direct responsibility for supply chain management with
training on trafficking and slavery (particularly on mitigating risk
within the supply chains of products).

Howbeit, The Act does not require that companies undertake any
efforts to combat human trafficking or slavery.

It only requires that covered companies disclose the extent of their

efforts on each of the required topics:

1. The company must disclose the extent of its efforts on each topic;
providing only a yes/no response as to whether the company
undertakes efforts with respect to each topic does not meet the
Act’s requirements.
2. The required disclosures must be posted in a conspicuous link on
the company’s internet homepage.
[Companies that do not have a website instead must provide written
disclosures within 30 days of the receipt of a request to any
consumer who requests them].

Penalties for non-compliance:

1. covered companies not in compliance with the Act likely face a
high probability of an inquiry or enforcement action from
regulators
2. Potential private consumer protection lawsuits based on alleged
violations of the Act is uncertain at this time because courts
have not yet determined whether such suits are permitted.

If you have any further questions regarding the CTSCA, please

contact the office.

Best Wishes

Olga Kyriakoudi