ONKYO U.S.A. CORPORATION

California Transparency in Supply Chains Act of 2010

Beginning in 2012, many companies manufacturing or selling products in the state of California are required to disclose their efforts to address the issue of forced labor and human trafficking, regarding the California Transparency in Supply Chains Act of 2010 (SB 657). This law was designed to increase the amount of information made available by companies with regard to efforts to eradicate forced labor and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Forced labor and human trafficking can take many forms, including child labor. ONKYO U.S.A. Corporation has a zero-tolerance policy for forced labor, child labor or other forms of human trafficking, slavery or abusive disciplinary practices.  ONKYO is committed to ensuring that our supply chain reflects ONKYO’s values and respect for human rights and the environment.

  • ONKYO’s relationships with suppliers are based on lawful, efficient and fair practices. We expect our suppliers (and their subcontractors and suppliers) to obey the laws, rules and regulations that require them to treat workers fairly, and provide a safe and healthy work environment.  ONKYO requires that our manufacturing facilities confirm in writing that they conform to these standards, and maintains a file of these certifications at its US corporate office.
  • ONKYO’s policy guidelines forbid the use of forced labor, child labor and physically abusive disciplinary practices.
  • In furtherance of this policy, ONKYO obligates its suppliers to comply with our Suppliers Expectations, including the requirement that they not utilize forced, prison, or indentured labor, or subject workers to any form of compulsion or coercion. ONKYO’s suppliers are obligated to expect the same standards of their suppliers in turn.
  • ONKYO does not currently conduct regular audits or engage a third party to audit, inspect or to evaluate risks of human trafficking and slavery of our existing suppliers. However, new suppliers are asked to confirm their adherence to our Supplier Expectations and, if they operate in a high-risk region or insufficiently demonstrate adherence to appropriate labor, ethics and compliance practices, or have previously been found to not so adhere, we reserve the right to conduct (or have an affiliate of ours or independent third party social compliance monitoring firms perform) announced and unannounced, on-site inspections and factory audits. Inspections and audits may consist of individual and group interviews with supervisors and management, as well as facility tours.  If we find deficiencies, deficient suppliers may have 90 days to make corrective actions. Suppliers that fail to meet ONKYO’s expectations are terminated.
  • ONKYO reserves the right to inspect and audit or have an affiliate or third party social compliance monitoring firm inspect and audit any factory and any supplier at any time, with or without advance notice for compliance with ONKYO’s Supplier Expectations based upon ONKYO’s risk assessment and any prior audit findings.

SUPPLIER EXPECTATIONS

ONKYO U.S.A. Corporation (“ONKYO”) expects its suppliers (and each of their subcontractors and suppliers involved in the manufacture, assembly and procurement of goods to be sold or delivered to ONKYO or its affiliates (each a “Subcontractor”) to treat workers fairly, respect freedom of association, prohibit discrimination and harassment, provide a safe and healthy working environment, and protect environmental quality.

ONKYO expects its suppliers (and each of its subcontractors) to comply with applicable local, national, regional and global laws, rules and regulations and to adhere to ONKYO’s standards and expectations.

 In this regard, each of our suppliers must:

  • Comply with laws and regulations protecting the environment, strive to improve their resource efficiency, and not adversely affect the local community.
  • Provide workers with a safe and healthy workplace.
  • Employ workers above the applicable minimum age requirement or the age of 16, whichever is higher.
  • Comply with all applicable laws and regulations governing wages, hours, days of service, and overtime payment for workers in the nations were the goods are manufactured or assembled.
  • Not utilize forced, child, prison or indentured labor.
  • Not subject workers to any form of compulsion, coercion or human trafficking.
  • Allow their workers to choose freely whether or not to organize or join associations for the purpose of collective bargaining, as provided by local law.
  • Prohibit physical, sexual or psychological harassment or coercion.
  • Assure that workers are hired, paid and otherwise subject to terms and conditions of employment based on their ability to do the job, not on their personal characteristics such as race, national origin, sex, religion, ethnicity, disability, maternity, age and other characteristics protected by local law. (Please note that this is not intended to bar or prohibit compliance with affirmative action laws, rules or regulations or other compulsory or appropriate policies that may be required by local law.)
  • Maintain and enforce a Company policy requiring adherence to ethical business practices, including a prohibition on bribery of government officials.
  • Respect the intellectual property rights of third parties.
  • Adopt policies and establish systems to procure columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives including tantalum, tin and tungsten (sometimes called “Conflict Minerals”) from sources that have been verified as conflict-free, and provide supporting data on their supply chains for such Conflict Minerals to ONKYO upon request.
  • Maintain security measures consistent with international standards for the protection of their operations and facilities against exploitation by criminal or terrorist individuals and organizations.
  • Expect their suppliers to conform to similar standards.

Any vendor desiring to do business with ONKYO must abide by our Terms and Conditions which, with the purchase order, constitute the contract under which we purchase goods. Our terms expressly require a vendor to represent and warrant that its goods (as well as all materials incorporated therein) are manufactured in accordance with these Supplier Expectations and all applicable laws

A supplier’s failure to correct any assessment findings inconsistent with ONKYO’s policies within 90 days from receipt of a notice of deficiency from ONKYO or such other designated time frames specified by ONKYO in the notice will results in termination of business without liability to ONKYO.

Concerns of ONKYO employees, or employees of suppliers or subcontractors may be anonymously reported to ONKYO and ONKYO reserves the right to investigate any such reports.