BIW complies with the California Transparency in Supply Chains Act (Cal. Civ. Code § 1714.43) (the “Act”) by doing the following:
1. Verification: In connection with BIW’s procedure for Determining Supplier Quality and Responsibility, all prospective suppliers are assessed by BIW Procurement to determine if they are qualified and responsible. Suppliers must be able to provide all required representations and certifications pertaining to compliance with laws, including such laws regarding slavery and human trafficking in the country/countries in which they do business. In addition, BIW uses the services of a third party to conduct restricted party screening. One component of the service includes screening of the Department of Homeland Security Investigations Most Wanted, which encompasses numerous categories including Human Trafficking/Smuggling.
2. Audits: BIW reserves the right to audit a supplier’s compliance with BIW’s terms and conditions, including but not limited to Compliance with Laws. Such audits would be conducted by BIW only if there were reason to believe that a supplier was not in compliance with BIW’s standards against trafficking and slavery in supply chains.
3. Certifications: BIW’s procurement procedure is in the process of being updated to require a signed certification from each supplier prior to the placement of any order and/or subcontract. The certification requires the supplier to represent and warrant that it is in compliance with laws pertaining to human trafficking and slavery in the country/countries in which they do business.
4. Accountability: General Dynamics’ Standards of Business Ethics and Conduct (“the Blue Book”) governs BIW’s ethics and business standards. The Code of Ethics states, among other things, that our employees will comply with applicable laws and regulations. Human trafficking and slavery are illegal, and constitute a violation of the Blue Book by an employee or supplier. Such a violation would result in disciplinary action against the employee. Any supplier found to be engaging in slavery or human trafficking will be subject to termination.
5. Training: BIW provides appropriate Procurement personnel with training on the Act and applicable federal regulations including those pertaining to human trafficking