DISCLOSURE PURSUANT TO CALIFORNIA TRANSPARENCY
IN SUPPLY CHAINS ACT OF 2010
As specified in the Company’s Guidelines on Business Conduct, Grain Processing Corporation and its parent company, Kent Corporation, is committed to conducting business with the highest standards of morality, fairness, and integrity and to adhere with the laws of the jurisdictions in which our business takes place. In these Guidelines, the Company expressly states that it does not accept or support the use of illegal, forced or child labor within its operations anywhere in the world and shall not knowingly purchase supplies from suppliers who engage in slavery or human trafficking. GPC requires all of its employees to comply with the Guidelines.
As a practical matter, Grain Processing Corporation is an Iowa, USA business that manufactures its products in the United States, where its two principle manufacturing plants are subject to U.S. and state laws and regulations regarding, among other things, forced labor and human trafficking. GPC’s supplier base is also predominantly U.S.-based. The main ingredient in our products is corn, which is our largest purchase by far. This corn is sourced in the U.S. and produced by U.S. farmers that are also subject to U.S. and individual state laws regarding forced labor and human trafficking.
GPC has a dedicated purchasing department and separate commodities department that, together, ensure the Company works with reputable suppliers. Our purchasing and quality assurance teams are responsible for verifying the quality of the supplies we buy as well as the integrity of the suppliers which provide them. GPC holds such suppliers to the highest industry standards, which enables us to produce quality, consistent products in turn for our customers. At a minimum, all GPC suppliers are expressly required to comply generally with all laws applicable to the production of the products they supply to GPC.
With specific regard to the California Transparency in Supply Chains Act of 2010, GPC states it has sought certification from some key, non-farmer suppliers that the materials provided to GPC comply with the laws regarding slavery and human trafficking of the country or countries in which the supplier is doing business. Otherwise, in light of the realities of where GPC sources the vast majority of its supplies, GPC does not currently (1) engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery; (2) conduct audits of suppliers to evaluate supplier compliance with laws for trafficking and slavery in supply chains; (3) require all direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business; (4) maintain internal accountability standards and procedures for employees or contractors failing to meeting standards regarding slavery and human trafficking; or (5) provide employees and management who have direct responsibility for supply chain management training on human trafficking and slavery. GPC will continue to review its supply chain management practices and take those steps we deem appropriate to make sure we can continue to produce superior products for our valued customers.