Effective Date: This policy is effective as of January 1, 2019.
At Smart Pet Food, we believe everyone touched by our business should be treated with fairness, dignity and respect. We are a global, principles-driven company seeking to promote and advance respect for human rights across our value chain - from farms to our suppliers’ factories to our own workplaces. Our goal is to work with partners who share our principles-based approach to business, and we expect our first-tier suppliers to respect human rights in their workplaces. Our global human rights approach includes first-tier suppliers
On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. Under the law, manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s underlying purpose is to educate consumers, so they can make informed decisions and purchase goods from companies that responsibly manage their supply chains.
We hold ourselves and our vendors accountable to high ethical standards wherever we do business. Smart Pet Food works diligently to ensure that our products are produced ethically by our suppliers and in accordance with Smart Pet Food’s Standards of Vendor Engagement (“Smart Pet Food’s Standards”), which Smart Pet Food’s suppliers are subject to as a condition of doing business with us. Smart Pet Food also undertakes enhanced compliance verification efforts for all vendors producing Smart Pet Food owned-brand goods overseas.
As good corporate stewards, Smart Pet Food will not work with any suppliers that engage in human trafficking and/or slavery. As part of our social responsibility program, we conduct audits which serve as a starting point to understand suppliers' compliance infrastructure. Issues such as human trafficking, slavery, forced/prison labor and child labor are zero tolerance violations and Smart Pet Food will not only not conduct business with suppliers having such practices, but will also report them. Our audits allow us to verify that all labor at our suppliers' factories is voluntary.
As a condition of doing business with Smart Pet Food, all of our suppliers warrant that the products they supply to Smart Pet Food, whether private label brand or Smart Pet Food’s owned-brand, are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. Smart Pet Food’s Standards expressly prohibit our suppliers from utilizing any forced or compulsory labor. They also mandate that workers receive fair wages and benefits in compliance with all applicable laws. Smart Pet Food will not do business with a vendor that fails to warrant such compliance. Moreover, Smart Pet Food will cease to do business with a vendor who fails to live up to that promise, and will also take actions toward reporting them,
VERIFICATION OF SUPPLY CHAIN
Smart Pet Food uses an enterprise risk management (ERM) process to identify and assess major risks to the company. Human rights violations in Smart Pet Food’s supply chain are an identified risk on the ERM process which is reviewed and updated on an annual basis.
We also use third-party supplier risk assessment to help identify and verify risk, including indicators of forced labor, and inform the types of actions we take with both current and new suppliers. Based on publicly available information and advice from experts, we’ve identified extended supply chains in which human rights risks are high and where we are actively engaging – for example, cocoa, palm oil and fish.
We have high human rights expectations of all first-tier suppliers, including workplace standards and guidelines aligned with the International Labor Organization’s Fundamental Principles and Rights at Work. It prohibits the use of prison, slave, bonded, forced and indentured labor and human trafficking. The following areas are included in our expectations of suppliers:
Forced labor, including slavery and human trafficking
Abuse, harassment, disciplinary action
Fair and equal treatment/non-discrimination
Compensation and benefits
Freedom of association and collective bargaining
Health and Safety
Ethical business practices
We encourage suppliers to implement relevant systems to manage risk in their own operations, such as confidential grievance mechanisms. Suppliers have an important role in promoting responsible sourcing policies and principles in their own supply chains, and as part of our commitment to building supplier capability, we periodically engage suppliers in training and awareness raising to drive continuous improvements.
AUDITS OF SUPPLIERS
We evaluate human rights risks associated with operating in specific geographies or purchasing specific commodities and services. We work with suppliers accordingly to assess and improve how they manage these risks and their implementation of our expectations. If a supplier repeatedly fails to meet our expectations and other verification standards and does not credibly commit to meeting them in a given time period, we may terminate our relationship with that supplier.
Additional tools, may include further desk research, self-assessment questionnaires, audits and rapid human rights risk assessments. For example:
Risk assessment - We may use independent country, commodity, and product risk data provided to score and assess the social and environmental risks associated with what we buy and where we buy it. Forced labor and related risks are included in this data, which is based on publicly available information from sources such as the U.S. Department of Labor. Risk assessment helps us determine, based on our requirements, the actions expected of specific suppliers, which could include self-assessments or independent audits.
Independent Auditing – Select suppliers are further required to have an independent third party conduct workplace assessments based on a range of factors, such as whether they are operating in a high human rights risk geography.
CERTIFICATION OF SUPPLIERS
Smart Pet Food requires international suppliers to comply with all applicable laws and regulations in the jurisdictions in which they operate. With each shipment of products to us, all vendors must provide a signed certification that the products they provide to us, and the materials incorporated into these products, comply with the laws and regulations regarding slavery and human trafficking of the country or countries in which they do business. Vendors must also certify that any vendor or subcontractor used in the manufacturing or in the distribution of the products they provide complies with these standards.
We expect our suppliers to align with our expectations, including its provisions on forced labor, by affirming their commitment to uphold our expectations or demonstrating an equivalent policy of their own. Suppliers are expected to maintain transparent records to demonstrate compliance with applicable law and regulations.
Smart Pet Food also use a Master Vendor Agreement to the majority of our vendors, both domestic and international. This Agreement requires that our suppliers comply with all U.S. and foreign laws governing the products the vendor supplies to Smart Pet Food, including laws related to the manufacture of the products. Smart Pet Food’s purchase orders contain terms and conditions requiring that our vendors’ products comply with all applicable federal, state, provincial, and local laws, including those governing manufacturing.
If a vendor fails to comply with any of the above requirements, Smart Pet Food promptly reviews the failure with the vendor to determine a solution, if possible. Smart Pet Food ceases to do business with vendors that cannot maintain these requirements.
ACCOUNTABILITY AND TRAINING
Smart Pet Food has a zero-tolerance policy regarding forced labor within our company, as well as in relation to our suppliers. If forced labor is found in a supplier’s factory, the factory is immediately deactivated from Smart Pet Food’s approved factory list and any merchandise in production there will not be accepted.
Smart Pet Food administers mandatory training for team members responsible for sourcing and merchandising decisions on an array of topics, including our Standards and Social Compliance responsibilities. We also require team members to comply with strict business conduct guides, which includes a review of our Standards. Our trainings emphasize strong social compliance management practices and focus on preventing and managing related issues, including human trafficking and slavery.
All Suppliers that sign Smart Pet Food Code of Conduct must adhere to our comprehensive social responsibility requirements and are to follow all law and regulations in the jurisdictions in which our products are manufactured.
MODERN SLAVERY ACT STATEMENT
We believe that forced labor in any of its forms has no place in our operations or supply chains and that business, government and civil society must work together to make progress on this complex issue. Our Modern Slavery Act disclosure details our efforts to address forced labor, including modern slavery and human trafficking, which are core components of our global human rights strategy and programs.
CONFLICT MINERALS - CALIFORNIA PROPOSITION 65 COMPLIANCE
Smart Pet Food understands that political, social, or economic conflicts may be directly or indirectly financed by the mining of and trade in “conflict minerals.” The term “conflict minerals” refers to tin, tungsten, tantalum, and gold (“3TG minerals”), and the ores from which they originate, that are mined in the DRC region. The 3TG minerals are present in the manufacture of a variety of commercial products, including some of our products. Because of our support for the human rights of all people and our concern that materials in our supply chain may be inadvertently used to limit human rights, we are taking additional steps to understand whether any 3TG minerals that may be contained in our products are used to finance the conflict in the DRC region. As such, we will take the following steps to determine the use, source and origin of 3TG minerals in our global product portfolio across our business segments:
1. Work closely with our suppliers to determine the potential use of 3TG minerals in our supply chain and, when appropriate, work with them to remediate issues and source more responsibly.
2. Expect that any of our suppliers that may use 3TG minerals to conduct the necessary inquiry and, where appropriate, additional due diligence to provide us with confirmation of the source of the materials used in their processes and ultimately present in our products.
3. Encourage our suppliers to advocate and actively action our philosophy of sourcing 3TG minerals from socially responsible suppliers, including conflict-free mines in the DRC region.
California's Proposition 65 (Prop 65) entitles California consumers to receive special warnings for products that contain chemicals known to the State of California to cause cancer and birth defects or other reproductive harm if those products expose consumers to such chemicals above certain threshold levels. We know you're concerned about product safety and Smart Pet Food takes all necessary steps to comply with all applicable safety and health requirements.
On enjoyforpets.com, we provide a Prop 65 link under Other Info for each item that requires the Prop 65 warning. If a Prop 65 link does not appear in the Other Info section for the product you wish to purchase, the supplier of the product has indicated that it does not require the Prop 65 warning. Nevertheless, the general Proposition 65 notice is as follows:
WARNING: This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm.
In addition, there may be specific warnings for the following products if the product includes a link to this page in the Additional Info tab:
1. Ceramic Tableware - WARNING: Use of this tableware will expose you to lead, a chemical known to the State of California to cause birth defects or other reproductive harm. Patterns identified with the yellow triangle symbol are the ones for which this warning is given.
2. Lead Crystal Products - WARNING: Consuming foods or beverages that have been kept or served in leaded crystal products will expose you to lead, a chemical known to the State of California to cause birth defects or other reproductive harm.
3. Painted or Decorated Glassware - WARNING: The materials used as colored decorations on the exterior of this product contain lead, a chemical known to the State of California to cause birth defects or other reproductive harm.
PVC Coated Products or PVC Coated Wires, Cords, Plugs & Connectors - WARNING: The plastic on this product contains lead, a chemical known to the State of California to cause cancer, and birth defects or other reproductive harm. Wash hands after handling.
As you can see from above, our actions on conflict minerals support and evidence of Marketfleet’s long-term commitment, are direct towards respecting the human rights of all people and to improve the quality of life in the communities we serve.
Please send any questions or comments (including all inquiries unrelated to copyright infringement) regarding this Site to:
Smart Pet Food, LLC.
3401sw 160 AV., SUITE 330,
MIRAMAR, FL 33027.