Our Policies and Code of Conduct

California Transparency in Supply Chains Act (SB-657)

In 2010, the State of California enacted the California Transparency in Supply Chains Act (‘SB-657’) (‘the Act’), requiring businesses to disclose the efforts they are making, if any, to eradicate human trafficking and slavery [1] from their supply chains.

The law went into effect on January 1, 2012.

SB-657 requires retailer sellers and manufacturers doing business in California that exceed $100 million in global revenue to publicly disclose the degree, if any, to which they are engaging in verification, auditing, and certification of their direct suppliers, maintaining internal accountability standards, and providing internal training regarding trafficking and slavery in their direct supply chains for tangible goods offered for sale.

About PCH

From startups to Fortune 500s, PCH designs custom manufacturing solutions for the world’s best brands. This involves everything from product design engineering and development, manufacturing, packaging and fulfillment, distribution and retail, and ultimately the customer out-of-box experience. We are proud to be responsible for some of the most successful consumer electronics accessories launches. Our clients are located all over the world, from the technology giants of Silicon Valley to startup companies looking to bring their ideas to the world.

Sustainability at PCH

At PCH, we believe that Sustainable business practices make better business. Beyond that, we believe it is the right way to do business. PCH has a dedicated Sustainability team based in Shenzhen, China which is helmed by the Head of Sustainability and the Head of Supplier Development. We also have a Supply Base Management and Quality team who are responsible for sourcing suppliers and qualifying them for entry to the PCH supplier network.

The PCH Supply Chain

PCH has access to a diverse network of suppliers, the majority of which are based in China. PCH has engaged with over 1,000 factories since we came to China in 1996 and in turn, thousands of workers form part of our network. Our level of engagement varies on an annual basis depending on the number of active projects that we have each year. Our supplier partners include electronics assembly, hard good engineering, soft goods, printing and packaging and industrial equipment and supplies.

Zero Tolerance on Slavery and Human Trafficking

We operate a ‘zero tolerance’ policy towards these behaviors and would never accept this in our own or our suppliers’ factories. Slavery and human trafficking are risks in the manufacturing industry, particularly in China. [2] As active participants in this industry, we at PCH are committed to preventing and reducing the risk of these practices in our supply chain.

PCH operates a Supplier Code of Conduct which is monitored through annual audit and through constant PCH engagement with our direct suppliers year-round. Our audit programs were developed using Electronic Industry Citizenship Coalition (‘EICC’) guidance and client & industry standards. All audits check suppliers’ practices for, amongst other criteria, child labor and youth workers, disciplinary practices and forced labor. We disclose the audit qualification process and results of these audit findings and our procedures in our annual PCH Sustainability Report.

The majority of suppliers sign the PCH code which expressly prohibits forced, bonded or indentured labour, child labour or inhumane treatment. In some instances, suppliers who already have equivalent legal agreements in place with our clients do not sign our Code of Conduct.

If a potential supplier is found to conduct any zero tolerance practices, we will not accept them as a supplier. If an existing supplier is found to have engaged in any zero tolerance practices, they automatically fail their audit and, depending on the circumstances, we either terminate the relationship or endeavor to assist them to put a remediation plan in place, granting them a maximum of three months to rectify the situation before they are reaudited.

The PCH Quality team conducts audits of all suppliers that qualify for an audit. Audits are announced and scheduled, so that we can build trust and long-term relationships with our supplier partners. Audits are conducted by at least two PCH auditors who spend at least one day onsite at the suppliers’ location. A meeting is held after the audit with the supplier and PCH Client Quality Manger to explain the findings and any requests for follow up.

Audits set an important baseline in any rigorous labour and human rights program. But we must treat audits as the beginning, and not the end of our engagement with suppliers. It must be acknowledged, however, that despite these measures, it is difficult to verify such practices and there could be incidences of slavery and human trafficking as well as other human rights infringements in some factories in the region in which we operate. In our experience, building out a trusted network of local suppliers and maintaining a PCH presence in those factories is the most successful mode of preventing slavery and human trafficking.

Suppliers who fail to meet our Code of Conduct are in breach of our agreement. For more information please see our 2013 Sustainability Report. At this time, we do not require, but we encourage, our Suppliers to audit their sub suppliers or certify that materials incorporated into the products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Worker Hotline

We partner with Little Bird who operate an independent hotline in our own, and in three supplier facilities. This provides a source of feedback and communication with our factory workforce and offers all factory workers an avenue to report any labour or human rights grievances.

PCH Employees

All PCH employees are expected to respect labour and human rights in our own and our suppliers’ operations. Should any employee have concerns about our labor or human rights practices, they can approach their direct managers, any member of management and any member of HR to share their concerns.

For more information on Sustainability at PCH, or to view our Sustainability Reports, please visit here.

[1] The UN defines human trafficking as “the recruitment, transportation, transfer, harboring or receipt of persons, by means of threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs” (UN Protocol to Prevent, Suppress, and Punish Trafficking in Persons).

[2] Estimated .2% of Chinese population are in modern slavery with reports of slavery in amongst others, the manufacturing industry. The International Labour Organisation (‘ILO’) ranks China second only to India for the highest absolute number of enslaved people.
The Global Slavery Index which presents a ranking of 162 countries, based on a combination of estimated prevalence of modern slavery by population, levels of child marriage, and levels of human trafficking ranks China number 84

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