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Thanks! Of course, to say we are in compliance, we need to pass further acknowledgements down through our supply chain as well...
You are correct. The goal of SB 657 is primarily awareness. Here is one example of how one company is providing such acknowledgement. This is not mean as a certification merely an acknowledgement that you are aware on the prohibition of slavery and other human trafficking.
In essence you need to provide your sub-supplier with a form acknowledgement / questionnaire that they will provide to you in it they will acknowledge that they do not engage in such conduct (if they push back you can adjust the language to reach that to the best of their knowledge they do not engage in such activities)
being this the first law of its kind the vast majority of businesses are not aware of it and have never seen such an acknowledgement so it will take some explaining on your part
To my knowledge the statute does not specify penalties although the franchise tax board is requested to review a yearly list of retail establishment so this could mean that something would be introduced
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what is the penalty for noncompliance? Is this just a feel-good thing or does it have teeth? We have a limited staff to deal with such issues and would have to enforce this on our MANY subcontractors and go through the detailed FDA quality documentation process to do so.
As noted, at this time other than the requirement by the franchise tax board to create a roll call of businesses, I am not aware of any penalty or consequence for non-compliance. I do suspect that something is brewing, otherwise why task the franchise tax board with work...?
is it unusual for a regulation to have no penalty for violation/noncompliance?
Not necessarily. Here's the language of the statute.
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