The Devil Is In 'Where To Disclose' Supply Chain Details

Law360, New York (February 14, 2013, 10:16 AM EST) -- As companies around the globe are beginning to understand, the California Transparency in Supply Chains Act of 2010 (effective Jan. 1, 2012, and deconstructed here) requires all retail seller and manufacturers with over $100 million in annual worldwide gross receipts that “do business” (a low threshold) in California to disclose on their websites what efforts, if any, they have taken to eliminate forced labor and human trafficking from their worldwide supply chains. (A description of the required disclosures is available here.)

While most compliance and supply...
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