Statement Regarding California Transparency in Supply Chains Act
Pursuant to the disclosure requirements of the California Transparency in Supply Chains Act of 2010, Grill Concepts, Inc. and its subsidiaries and affiliates (collectively, "GCI") herein provide a description of our policy with regard to efforts to eradicate slavery and human trafficking from supply chains. Members of the GCI supply chain are not only selected because of their trustworthiness, performance, and commitment to excellence, but also because they adhere to certain ethical standards and embrace shared values. It is GCI's policy that no product in the supply chain shall be produced in violation of any labor, health, or other laws, including laws prohibiting slavery and human trafficking. In connection with slavery and human trafficking, GCI shall require members of our supply chain to develop eradication programs that may include some or all of the following:
A) Verification by GCI's distributors and vendors of product supply chain practices to evaluate and address risks of human trafficking and slavery and to affirm that all products purchased for or supplied to GCI were made in compliance with applicable labor laws, including laws prohibiting slavery and human trafficking. At present, GCI does not directly utilize third party verification procedures.
B) Audits by GCI's distributors and vendors to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. At present, GCI does not utilize independent, unannounced audit procedures.
C) Supplier, distributor and/or vendor assurance that work and materials incorporated into the products supplied to GCI complies with the laws regarding slavery and human trafficking of the country or countries in which each supplier is doing business.
D) Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
E) Training of company employees and management, who have direct responsibility for supply chain management, particularly with respect to mitigating risks of slavery and human trafficking and violations of company policies.