A manufacturer doing business in California that has annual worldwide gross receipts exceeding $100 million is required by the California Transparency in Supply Chains Act (effective January 1, 2012) to disclose its efforts to eradicate slavery and human trafficking from its global supply chain.

The Act empowers the California attorney general to bring injunctive relief actions against companies to enforce compliance with the Act. The Act directs the California Franchise Tax Board to provide the state's attorney general with a list of companies required to disclose based on tax returns filed for taxable years beginning on or after January 1, 2011. The initial list was given to the attorney general on November 30, 2012, and a new list will be submitted each year on November 30.

For more information on this topic, read Holland & Knight's Corporate Social Responsibility Compliance Alert.