Rana Meal Solutions, LLC:
Statement in Compliance with CA Transparency in Supply Chains Act
(California Civil Code Section 1714.43)

 

California Civil Code Section 1714.43 generally requires that any seller or manufacturer doing business in California disclose the extent of any efforts of the seller or manufacturer to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale. Rana Meal Solutions, LLC (“Rana”) is firmly committed to the eradication of slavery and human trafficking in all aspects of its business and operations and in those of its suppliers.

Rana is firmly committed to a work environment in which all individuals are treated with respect and dignity, and to further those interests, Rana has instilled a culture of sensitivity, awareness, and action to address any conduct in its operations and direct supply chain which furthers or could further slavery or human trafficking. Specifically, Rana has committed to the principles articulated in Social Accountability Standard 8000 (“SA8000”) – the world’s leading social accountability standard. Among other areas, SA8000 measures performance by businesses in their efforts to identify and eradicate child labor as well as forced and compulsory labor. Rana’s compliance with SA8000 has been regularly audited by a third party and Rana proudly maintains its SA8000 certification.

 
 

Rana’s Verification that Its Direct Supply Chain Is Free of Slavery and Human Trafficking.

Rana has undertaken a number of actions in order to verify that its supply chains are free of human trafficking and slavery, and to address risks of the same occurring in its direct supply chain. Through its Supplier Code of Conduct as well as it Purchaser Terms and Conditions, Rana demands that its suppliers affirmatively warrant and certify to Rana that their operations and supply chains are free of slavery and human trafficking. Suppliers are also asked to certify and warrant in connection with each transaction with Rana that they do not engage in any activities which may reasonably be considered to constitute or further human trafficking or slavery, and that they do not intend to engage in any such activities in the future.

In addition to these warranties and certifications, Rana’s suppliers are each required to cooperate with Rana’s efforts to audit and verify its suppliers’ adherence to their commitments against slavery and human trafficking. Upon request, Rana’s suppliers are asked and expected to timely provide Rana the name(s) of the person or persons principally responsible for the supplier’s auditing/monitoring of human trafficking and slavery compliance for purposes of facilitating Rana’s own audit and verification process. Further, Rana’s suppliers are asked and expected to reasonably cooperate with Rana’s efforts to verify and evaluate its supply chains to address risks of slavery and human trafficking.

The verification process established by Rana includes a combination of first-party verification checks and audits by Rana, as well as an expectation of reasonable third-party cooperation by Rana’s suppliers (which itself is a requirement of their continuing to do business with Rana). Rana reserves the right to terminate its business relationships with suppliers that do not cooperate with Rana’s requirements and expectations in connection with its efforts to assure that its supply chain is free of slavery and human trafficking.

 
 

Rana’s Audits of Its Suppliers

In furtherance of the above requirements, Rana has designated its COO with responsibility for conducting periodic checks and audits of Rana’s suppliers to confirm their adherence to Rana’s policies and requirements regarding the eradication of slavery and human trafficking in its direct supply chain. Rana is in the process of establishing a protocol for conducting such audits and verifications, and it will provide full details of that process once fully established. Nevertheless, Rana’s intent is not to announce such checks and audits to its suppliers in advance, other than to make suppliers aware that these checks and audits may occur and to request identification of points of contact with suppliers in connection with such audits.

 
 

Certification by Suppliers that Materials Incorporated In Their Products Are Compliant

In addition to the above, in connection with each purchase of supplies by Rana, Rana’s suppliers are required to affirmatively certify to Rana in the Purchase Terms and Conditions that all materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

 
 

Internal Accountability Standards and Procedures Regarding Slavery and Human Trafficking

Rana regularly maintains internal accountability standards and procedures for employees or contractors failing to meet its internal standards regarding slavery and trafficking. First, upon their employment, each employee of Rana (including management) is provided with a Policy Statement concerning the company’s commitment to comply with SA8000, including that Standard’s prohibitions of reliance upon any forced and compulsory labor. Rana also regularly audits its hiring and employment policies and practices to ensure their consistency with SA8000 and other employment laws governing the compensation of employees and voluntariness of its labor force.

Second, Rana’s employees (including management), upon their hire, are informed that the company has zero tolerance for any conduct which, in the company’s sole determination, is reasonably likely or intended to further the interests of slavery and human trafficking (including any intentional use of child labor). Rana advises each of its employees and managers that any material violation of these policies will be addressed through disciplinary actions up to and including termination of employment.

 
 

Training Addressing Human Trafficking and Slavery

Rana currently does not have a formal training program in place with respect to slavery and human trafficking. However, Rana is currently exploring third-party options to obtain such training for those employees and managers that have direct responsibility for supply chain management. Rana plans to update this statement once a provider with the appropriate expertise to best assist Rana with combatting these issues is identified and an appropriate training program is put in place.