California Transparency In Supply Chains Act Of 2010 Going Into Effect

California's Transparency in Supply Chains Act of 2010 (the Act) requires companies to publicly disclose their efforts to combat slavery and human trafficking in their business supply chains. The Act, which becomes effective Jan. 1, 2012, requires large companies doing business in California to post on their websites links to their anti-human trafficking policies, to enable consumers to make more informed purchasing decisions. While the Act does not mandate any required policies or their content, it does require that the policies (or lack of policies) be disclosed via a link available on the company's homepage.

The Act enables the attorney general of California to pursue injunctive relief but does not bar consumers or others from seeking available remedies for violations of other state or federal laws such as false advertising or misrepresentation. Accordingly, any policies posted in accordance with the Act must be accurate. The pertinent provisions and definitions of