California Transparency in Supply Chains Act of 2010 Disclosure
Havensight Capital L.L.C. d.b.a. as various trade names, (collectively, “Havensight Capital L.LC.”) is committed to legal compliance and ethical conduct for itself and expects the same of its vendors. Thus, Havensight Capital L.L.C.’s policy is to only do business with vendors who have certified to Havensight Capital L.L.C. that their business practices are lawful, and that vendors adopt and act in accordance with practices that create fair, safe, and healthy working conditions. Specifically, Havensight Capital L.L.C.’s vendors use commercially efforts to avoid directly or indirectly engaging in, promoting, supporting, or facilitating human trafficking and slave labor.
In accordance with the California Transparency in Supply Chains Act of 2010, Havensight Capital L.L.C. makes the following disclosures:
Havensight Capital L.L.C. requires its vendors to certify that their business practices are lawful and that vendors adopt and act in accordance with practices that create fair, safe, and healthy working conditions. Specifically, Havensight Capital L.L.C.’s vendors use commercially efforts to avoid directly or indirectly engaging in, promoting, supporting, or facilitating human trafficking and slave labor. To ensure accountability, Havensight Capital L.L.C.’s reserves the right to terminate its business relationship with any vendor who fails to provide such certifications or whose business practices, or the business practices of its own suppliers and subcontractors, are not lawful and in compliance with the principles set forth in Havensight Capital L.L.C.’s Vendor Agreement. Havensight Capital L.L.C. reserves the right to conduct verification and audits (including third-party verification and audits) of its suppliers regarding human trafficking and slavery. Havensight Capital L.L.C. has conducted general audits, without the use of third parties and on an announced basis, of certain of its suppliers, and has not observed violations with respect to human trafficking or slavery issues. Havensight Capital L.L.C. is currently considering whether and how to best use third-party supply chain verification and independent unannounced audits with its suppliers. Havensight Capital L.L.C. has provided management who has direct responsibility for supply chain management with training on Havensight Capital L.L.C.’s business practices, and vendor requirements, including those provisions relating to mitigating risks of human trafficking and slavery. Employees and management failing to meet Havensight Capital L.L.C.’s standards regarding slavery and trafficking are subject to disciplinary action.