It is Circle K Stores Inc. (“Circle K”) goal to abide by all federal, local and state laws that regulates our business operations. One such law is the California Transparency in Supply Chains Act of 2010 (the “ACT”) that requires those retailers and manufacturers doing business in California with over $100 million in worldwide gross receipts to indicate what efforts have taken by them to eliminate slavery and human trafficking and violations of child labor laws from their respective supply chains.
Circle K has not in the past nor will it in the future, tolerate forced labor of any kind or nature within its supply chain.
This Act requires Circle K to share publicly the steps it has taken to comply with this California law. For that reason, when applicable to doing business in California, agrees to:
Routinely assess the risks that may be related to its supply chains. This Assessment will be based upon 1) supplier quality performance; 2) the type of transaction; 3) the specific commodity purchased 4) the geographic location of the source; and 5) any other relevant criteria to abide by the intent of the ACT. The Assessment will be conducted internally on a routine basis and performed internally from time to time. There may be instances when Circle K may choose to retain external resources in conduct a risk assessment.
Conduct audits of its suppliers to monitor compliance with its contractual requirements and other related agreed upon terms and conditions. Such audits may be conducted both internally and externally, with or without advance notice or consent. In the event unsatisfactory audits are revealed, Circle K’s suppliers will be required to submit and complete corrective action plans within a specified timeframe. Suppliers will thereafter be required to confirm that items listed in the aforementioned action plan have been completed in a timely and satisfactory manner. Circle K reserves the right to audit a supplier’s compliance with its own internal company standards and policies pertaining to human trafficking, child labor and slavery
Make it known to each supplier that Circle K reserves the right to terminate relationships with suppliers if it is learned that they failed to comply with any of the legal requirements set forth in the ACT and/or such non-compliance was not addressed in a timely manner.
Discipline any employee who is found to violate any provision of the ACT which could include termination his/her termination. Each employee, along with a myriad of other federal, state and local laws, will be notified of the ACT at the time of hire as well as intervals during his/her employment with Circle K as well as being made available on the company’s internal electronic system known as InnerCircle.
Provide contact information to all of Circle K suppliers and employees should questions/concerns arise in relation to the ACT.