CA Transparency in Supply Chains Act

Although Altria’s companies’ operations and sourcing are largely concentrated in the U.S., we understand our actions may affect those beyond our borders. Respect for people is fundamental to the way we conduct business. Consistent with this goal, our companies support the elimination of human trafficking and slavery worldwide and work to develop and maintain business relationships with reputable suppliers who share our commitment to conduct business in a responsible manner in compliance with applicable laws. These values and our expectations for suppliers are outlined in Our Cultural Aspiration, Code of Conduct and Supplier Code of Conduct. We also collaborate with others in industry and society to address human rights issues where our companies have a role to play. Altria’s companies engage in the following actions to identify and eliminate human trafficking and slavery in their supply chains:

 

• Supplier Verification. Before engaging in business with a supplier, Altria’s companies take reasonable steps designed to know their suppliers, including establishing that the supplier is engaged in legitimate business activity. If a supplier operates in a region or industry known for having a high risk of labor violations, we may use a third party to conduct a social responsibility review of that supplier, including an assessment of compliance with labor laws. We are aware that some domestic growers that sell tobacco to our companies use farm labor contractors ("FLCs"). We require FLCs to have a current Farm Labor Contractor Certificate of Registration issued by the U.S. Department of Labor. If the FLC provides transportation or housing services, the FLC Certificate of Registration must also include an authorization for the FLC to transport migrant workers and house migrant workers as applicable.
• In addition, we have monitoring processes, including monitoring for social responsibility compliance, for the following purchase areas:
  • Direct materials;
  • Contract manufacturing organizations;
  • Tobacco growers; and
  • Tobacco suppliers.
• Supplier Requirements & Certifications. Our suppliers sign contracts requiring them to comply with applicable laws, including laws addressing child and forced labor, and, where applicable, other specific contract terms related to child and forced labor. In particular, domestic tobacco growers agree to comply with GAP Connection's Tobacco Certification Program as part of their agreement with us, which exceed the standards of U.S. labor laws. All other suppliers agree to comply with the minimum age requirements prescribed by applicable laws or the International Labor Conventions, whichever are higher, unless a specific contract contains stricter age requirements and agree not to use forced or compulsory labor. Suppliers are not currently required to certify that materials used in their products comply with slavery and human trafficking laws of the country or countries in which they are doing business.
• Supplier Assessments. Based on a range of factors including our evaluation of risk, we conduct supplier periodic reviews, announced assessments, on-farm visits and independent third-party audits. These assessments include a review against contractual requirements, applicable laws and Altria’s Supplier Code of Conduct, which includes a restriction on forced and compulsory labor. When we learn of non-compliance issues, we communicate them to the suppliers. We expect suppliers to take corrective actions to address these issues and keep us informed of their progress. In some situations, we require immediate action to achieve compliance, or we stop doing business with the supplier. In other situations, we take a continuous improvement approach and work with the supplier to improve their practices. Assessment and audit results can be found in our Corporate Responsibility Progress Snapshots. We don’t currently conduct unannounced audits.
• Internal Training & Accountability. Altria’s companies’ employees are required to comply with our Code of Conduct, which states that Altria does not condone the unlawful employment of children in the workplace, nor does it condone forced labor. All employees receive training on the Code of Conduct and are asked annually to acknowledge their commitment to follow the Code. In addition, employees must comply with Altria’s internal Child Labor & Forced Labor Practices Policy, which prohibits the unlawful employment of children and use of forced labor, and promotes those objectives in its companies’ supply chains. Employees are required to incorporate appropriate contractual requirements prohibiting forced labor and requiring compliance with appropriate standards regarding the minimum age and treatment of child laborers. Altria’s Code of Conduct and policies are enforced through internal compliance training and audits. Our companies investigate allegations of non-compliance. If allegations are substantiated, they are addressed as appropriate, including training (or re-training) and employee discipline. In addition, employees working with domestic tobacco growers receive annual training on labor management and human rights. Altria companies do not conduct additional training specific to human trafficking or slavery for other supplier managers.