Retailers and manufacturers doing business in California, with annual gross receipts of more than $100 million will have new disclosures to contend with. Effective January 1, 2012, retailers and manufacturers must disclose their efforts to eliminate slavery and human trafficking from their supply chain. This disclosure is supposed to be made on company website. If the company does not have a website, the disclosure must be made within 30 days of such information being requested by a customer.

The law is called the California Transparency in Supply Chains Act of 2010. The law requires the retailers and manufacturers meeting the gross receipts threshold to, at a minimum, disclose efforts in certifying that materials incorporated into products comply with relevant anti-slavery and trafficking laws in the countries where they are doing business. The law also requires maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

Since worldwide gross income is the dividing factor in determining who should be complying, the bill requires the Franchise Tax Board to make available to the California Attorney General a list of retailers and manufacturers meeting the threshold.