Supply Chain Transparency
California Transparency in Supply Chains Act and UK Modern Slavery Act Disclosure
(in compliance with Cal. Civ. Code § 1714.43 and Section 54 (Part 6) of the UK Modern Slavery Act)
At Georgia-Pacific LLC, we recognize the critical role we play in making products that improve lives and offer better solutions than other alternatives. Doing so sustainably requires that we balance the social, environmental and economic benefits and risks of our products, including how they are sourced, manufactured and used. Suppliers play a key role in our efforts to ensure that we manage our global supply chain in a sustainable way.
The Georgia-Pacific Supplier Sustainability Guidelines set social responsibility requirements for our global supply chain. These Guidelines require suppliers to provide safe and healthy working conditions, treat their workers with dignity and respect, and follow environmentally responsible practices. Related to human trafficking these guidelines make clear that suppliers must not use forced labor or involuntary prison labor.
Georgia-Pacific regularly notifies its suppliers of their obligation to comply with the Supplier Sustainability Guidelines. Contracts with our suppliers obligate them to produce the products that we buy in a way that complies with applicable laws and regulations.
Other than the audit, supplier certification, accountability and training processes described below, Georgia-Pacific does not have a separate verification process for evaluating and addressing the risks of human trafficking and slavery.
Direct Supplier Certification
Georgia-Pacific’s commitment to ensuring that its supply chain is maintained in a socially responsible way includes an expectation that suppliers not use forced labor in any of its forms, including human trafficking and slavery, to produce the products they provide to Georgia-Pacific. These expectations are set out in the Georgia-Pacific Code of Conduct and the Georgia-Pacific Supplier Sustainability Guidelines. In addition, contracts with our suppliers obligate them to produce the products that we buy in a way that complies with applicable laws and regulations; at this time, however, Georgia-Pacific does not require suppliers to certify that they are in compliance.
Supplier Audits and Accountability Standards
To monitor compliance with the expectations of the Georgia-Pacific Supplier Sustainability Guidelines, Georgia-Pacific itself, instead of a third party vendor, assesses a number of its more than 30,000 suppliers. In each audit cycle, suppliers are selected using a risk-based approach; supplier participation in this process is mandatory. GP’s audit process is an in-depth and ongoing process, with one audit cycle sometimes taking more than a year to complete.
The three-stage assessment process includes a review of supplier responses to a detailed request for information, including company standards for human trafficking and slavery in supply chains, as well as our broader social responsibility and sustainability policies. If during this review, Georgia-Pacific identifies any concerns or supplier responses require clarification, the supplier is moved into stage two, which includes a conference call or other meeting with that supplier to address the concern or clarification. If the issue cannot be resolved at this stage, the supplier is moved to stage three, which may include a supplier site audit. Depending on the nature of the concerns involved, these site audits may be unannounced. Failure to meet the Georgia-Pacific Supplier Sustainability Guidelines may result in discontinuation of the supplier relationship.
Training on Human Trafficking and Slavery
Since implementing this assessment process, Georgia-Pacific has educated its procurement organization and others in the organization on this process and the Supplier Sustainability Guidelines. Further educational efforts regarding these expectations may include face-to-face meetings, web-based seminars and computer-based training, and will focus on how employees can assist Georgia-Pacific in mitigating risks within its supply chain.
The Georgia-Pacific Code of Conduct prohibits all forms of forced or involuntary prison labor. All Georgia-Pacific employees receive training on the Code of Conduct, with periodic refresher training.
This statement is made and reflects the position of Georgia-Pacific as of October 30, 2018, and has been approved by:
Senior Vice-President – Sourcing