Human Rights and Anti-Human Trafficking Policy
Triumph Foods has a zero tolerance policy for all types of human trafficking in its operations and in the operations of all subcontractors, suppliers, and vendors in its supply chain. This includes, but is not limited to, forced labor trafficking and commercial sex trafficking.
Triumph Foods has implemented an Anti-Human Trafficking Program that complies with the Trafficking Victims Protection Act (TVPA), Federal Acquisition Regulation 52.222-50, the UK’s Modern Slavery Act of 2015, and California’s Transparency in Supply Chains Act of 2010. This program includes a company Anti-human Trafficking Policy; mandates annual training for executives, human resources, procurement and recruiting departments; mandates onboarding training for new employees; requires vendor certifications; and requires an annual audit of both its recruiting and procurement departments. Further, Triumph Foods provides a process for reporting and remediating potential policy violations of the Triumph Food’s Anti-Human Trafficking Policy and maintains a zero-tolerance policy on retaliation. This policy applies to all of Triumph Foods’ employees and suppliers.
In 2020, as a part of Triumph Food’s Anti-Trafficking Program implementation and awareness program, Triumph Foods will receive anti-human trafficking training for its executive management, human resources, procurement teams, and recruiting staff. Updated training will be provided each year. Further, Triumph Foods will notify and train all new employees on its Anti-Human Trafficking Policy during the new employee orientation process. All current and new employees will receive a copy of the updated employee handbook which will contain Triumph Food’s Anti-Human Trafficking Policy and reporting procedures.
Triumph Foods will also audit and evaluate its current supply chain for risks of human trafficking in the acquisition of goods and services. Currently, as required risk assessment, Triumph Foods has assessed that hog procurement is the greatest risk within its vendor supply chain. Accordingly, Triumph Foods is auditing those hog procurement suppliers first. Triumph Foods will require new suppliers to sign a Code of Conduct certifying that entity is not engaging in any human trafficking. Going forward, each new supplier will be required to complete a Code of Conduct during the vendor set up process and will undergo an individual risk assessment.
Triumph Foods continues to implement its formal Anti-Human Trafficking Program and will post and report annually how effective this program is each year.