In the wake of the recent negative publicity deluge, including a
segment on a national newsmagazine show, alleging labor violations
including the use of child labor, safety violations and unfair pay
practices, Apple released a third-party report detailing problems and proposed
solutions at one of its largest suppliers. This follows the January
1, 2012 effective date of the landmark
California Supply Chain Transparency Act (the Act).
As noted in Perkins Coie's March 12, 2012
Update, the Act imposes various explicit supply chain-related
disclosure requirements on certain retailers and manufacturers
having annual global receipts in excess of $100 million. The
California Franchise Tax Board estimates that some 3,200
multinational companies fall under the California Act's broad
Apple's report, combined with its prior disclosures on child
labor and other labor issues, underscores the importance not only
of (1) proactively managing supply chain labor practices but also
of (2) responding promptly, decisively and publicly to supply chain
transparency problems when they arise.
Depending on the organization, a sound supply chain due
diligence program tailored to avoid potentially devastating
legal/consumer/shareholder consequences might include:
A comprehensive Risk Profile
Review of existing supply chain policies, due diligence
materials, annual certifications and trainings
Remote and/or onsite audits of compliance with existing
Implementation of remediation and/or verification plans to
Who Can Help?
Contact counsel for advice on the broad range of sophisticated
compliance issues implicated by the growing focus on supply chain
due diligence. You can find additional information on our website
Investigations & White Collar Defense.
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guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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stimates place the amount of money illegally "laundered" through
United States banks in the hundreds of billions of dollars each year.1
For more than five decades, the U.S. government has attacked money
laundering, in part, through anti-money laundering ("AML") disclosure,
monitoring, and reporting requirements placed on financial institutions.
We recently notified you of the FDIC’s Financial Institution Letter 47-2013 , which urges directors and officers of financial institutions to examine their institutions’ directors and officers (D&O) insurance coverage to ensure adequate protection for themselves as well as their depositors and shareholders.
Comments made by Kara N. Brockmeyer, the Securities Exchange Commission’s chief of the Foreign Corruption Practices Act unit, and Charles E. Duross, deputy chief of the Department of Justice’s FCPA unit, at the recent International Conference on the FCPA suggest that both agencies are increasing their scrutiny of possible FCPA violations for the next year.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Last Friday’s edition of the New York Law Journal features an article in its "Outside Counsel" column authored by Mintz Levin colleagues Andrew Roth and Kim Gold, entitled Cracking Down on Executive Compensation for Not-for-Profits.