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Legal Statements

California Transparency in Supply Chains Act of 2010 Disclosure

The California Transparency in Supply Chains Act of 2010 (the “Act”) requires companies to disclose their efforts to eradicate slavery and human trafficking from its direct supply chain. Broadridge is committed to ensuring that our supply chain is free from slavery and human trafficking. To that end, Broadridge has adopted a Human Rights Statement of Commitment to address the prohibition of the use or participation in slavery and human trafficking directly or indirectly through its supply chain.

Broadridge provides the following summary of its efforts to responsibly manage the supply chain.

Verification. Broadridge requires suppliers to respond to a survey to verify their awareness of and actions to eradicate slavery and human trafficking. Upon receipt of suppliers’ responses, any unacceptable answers will be followed up with further investigation.

Auditing. Broadridge reserves the right to conduct audits of suppliers to determine suppliers’ compliance with the Act. Any supplier that fails the audit will be advised why they failed and instructed on what is needed to become or remain a Broadridge supplier. Audits may be conducted by Broadridge or a third-party consultant and be announced or unannounced.

Certification. Suppliers for Broadridge must certify that materials used and/or incorporated into any product purchased comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Internal Accountability. Broadridge requires its employees to follow its Human Rights Statement of Commitment. Employees that fail to comply are subject to disciplinary action.

Human Rights Statement of Commitment

Broadridge is committed to respect that all human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood. Everyone is entitled to all the rights and freedoms without distinction of any kind, such as race, color, sex, language, religion, political or other opinion, national or social origin, property, birth or other status. Everyone has the right to life, liberty and security of person. No one shall be held in slavery or servitude; slavery and the slave trade be prohibited in all their forms; no one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. 

Prohibition of Human Slavery 

Broadridge is against all forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom and forced or compulsory labor, including forced or compulsory recruitment of children for use in armed conflict; the use, procuring or offering of a child for prostitution, for the production of pornography or for pornographic performances; the use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs as defined in the relevant international treaties; and work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children. 

Expected Standards from our Suppliers 

The Suppliers will not employ anyone against their will or force them to work. Employees have to be free to leave employment following reasonable notice. It must not be required for employees to hand over government issued identification, passports or work permits as a condition of employment. The Supplier must allow workers to openly communicate with management regarding working conditions without fear of reprisals of any type. Employees need to have the right to associate freely, and see representation. The Suppliers will adhere to the federal, state and/or international fair employment practices including but not limited to: hiring, termination, equal pay and discrimination. 

Due Diligence Process/Assessment 

Broadridge reserves the right to evaluate, including, but not limited to an onsite audit, of its suppliers to review the risks of human trafficking and slavery and may use a third party for such evaluation. Broadridge reserves the right to conduct unannounced audits of our suppliers for trafficking and slavery in the supply chain to evaluate compliance with company standards. Broadridge standard terms and conditions require compliance with applicable laws including laws against human trafficking and slavery. 

Accountability/Training 

Broadridge provides annual training to all associates, temps, contractors, and individuals who have direct responsibility for supply chain management, to understand and comply with its commitment on human trafficking and slavery. Associates, temps, and contractors who fail to comply will be subject to disciplinary action up to and including termination.