United Natural Food Inc.’s
Disclosure under the California Transparency in Supply Chains Act of 2010
January 2012

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their own direct supply chain. While UNFI is neither a retailer nor a manufacturer, it is nonetheless committed to meeting the requirements of the Act and expects its suppliers to as well.  The following is UNFI’s disclosure under the Act:

1. Ethical Commitment / Internal Accountability

UNFI is committed to conducting its business in a lawful and ethical manner and expects its employees, contractors and suppliers to conduct themselves in the same manner.  In that spirit, UNFI is committed to compliance with the California Transparency in Supply Chains Act.  All of UNFI’s employees, contractors and suppliers must adhere to its Code of Conduct, which requires compliance with all laws, including laws addressing slavery and human trafficking.

2. Updated Code of Conduct

UNFI recently updated its Code of Conduct to integrate the Act’s certification requirements.  UNFI strongly supports the goals of the Act and is committed to helping eradicate slavery and human trafficking for more information read UNFI's updated Code of Conduct.

3. Compliance within UNFI’s Supply Chain

UNFI is in the process of requiring all of its direct suppliers to certify that they and the producers/growers of food, goods and materials used by them in the products they sell to UNFI comply with UNFI’s standards with respect to slavery and human trafficking.  In its efforts to confirm compliance with the specific provisions of UNFI’s Code of Conduct and to confirm and document compliance with the Act, each of UNFI’s suppliers has been asked to certify to the following:

(i) It has verified product supply chains to evaluate and address risks of human trafficking and slavery, including disclosing whether the verification was done by a third party;
(ii) It has conducted supplier audits to evaluate compliance with company standards, as well as specifying whether the audit was independent and unannounced;
(iii) It requires direct suppliers to certify that the products comply with the laws of the country in which the supplier does business;
(iv) It maintains internal accountability standards for employees and contractors that fail to meet company standards concerning human trafficking and slavery; and
(v) It makes sure that employees and management who have responsibility for supply chain management are trained on trafficking and slavery, particularly on how to mitigate risks within supply chains. 

Any supplier that is not able to provide certification to the above will be required to provide UNFI with an action plan to achieve compliance within a reasonable period of time.  Further, UNFI will terminate its relationship with any supplier who fails to comply within a reasonable period of time.

You can view the letter UNFI sent to its suppliers and the required Certification - UNFI letter to suppliers regarding required Certification.

Related Links:

CA Transparency in Supply Chains Act

CA Transparency in Supply Chains Act FAQ