DS Services of America, Inc. is committed to conducting its business in accordance with the highest ethical and moral standards in all of our operations. In furtherance of this commitment, DS Services supports the goals of the California Transparency in Supply Chains Act of 2010. Not only does DS Services expect its associates and suppliers to be in full compliance with all laws and regulations, but also to conduct themselves ethically with regard to human rights and labor practices in all business dealings with and for DS Services. DS Services' commitment to ethical business dealings is reflected in how we treat each other, our customers and our suppliers. At DS Services, compliance with the law means observing both the letter and spirit of the law and conducting our business affairs so that we maintain the highest respect in our industry.
DS Services expects and believes that our suppliers will treat their workers ethically and allow them the right to freely choose employment, to join or be represented by worker councils or labor unions on a voluntary basis, and to bargain collectively as they choose. DS Services opposes human trafficking in all its forms and is committed to the goals of the California Transparency in Supply Chains Act of 2010 through the following efforts:
DS Services Company Policies and Guidelines states, "Associates are expected to exercise due diligence in selecting and retaining any third party (e.g., consultants, representatives, suppliers, independent contractors) to supply, represent, or perform work for DS Services." Our supply chain evaluation includes the assessment of risks such as human rights and labor violations. In the event concerns arise, we will investigate and take appropriate action to mitigate the risk and ensure the supplier is in compliance with all applicable laws and with our ethics policies.
At DS Services, all procurement associates who deal directly with our suppliers are encouraged to report all violations of law and company policy to their supervisors, including suspected slavery or human trafficking. DS Services also provides a toll-free hotline to all associates who wish to report various issues on an anonymous basis, including ethical and legal violations. Procurement associates who have knowledge of a supplier engaging in slavery or human trafficking and fail to report it may be subject to discipline, up to and including termination.
DS Services strives to include representations in all of its purchasing agreements and purchase order terms and conditions with direct suppliers, thus verifying that they comply with all applicable laws and regulations, including those protecting human rights. Although DS Services does not currently require all of our suppliers to specifically certify that materials incorporated into their products comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business, DS Services is committed to reviewing and revising its supplier contracts and arrangements to help ensure that our suppliers' products (including any material incorporated in the product) fully comply with all laws, including human rights laws, and that the supply chain is free from risk of human trafficking or slavery.
If DS Services becomes aware of any possible risk that a supplier is not acting ethically with regards to human rights it will perform an internal audit. Because DS Services does not believe this risk in its supply chain is significant, DS Services has not audited its suppliers for compliance. DS Services currently is reviewing its internal procedures in this regard and may institute an appropriate internal auditing process, or a third party audit process, in the future for any suppliers that it determines present a risk of human rights violations. DS Services reserves the right to verify that all of our suppliers are in compliance with all applicable agreements, laws and regulations, including the protection of human rights and the enforcement of ethical labor practices.
A copy of the DS Services Company Policies and Guidelines has been provided to all DS Services associates, each of whom provided an acknowledgement of receipt. DS Services also provides supplemental training on company policies and compliance to appropriate associates as befitting their respective roles within the organization. In 2012, DS Services plans to implement additional training on slavery and human trafficking as part of its training for procurement professionals, including how to identify and mitigate supply chain risks.