The week of August 17, 2015 has been a wakeup call to supply chain managers and compliance officers of companies doing business in the United States. On August 19, 2015, a consumer filed a putative class action against Costco Wholesale Corporation and several of its suppliers in Monica Sud v Costco Wholesale Corporation, et al., Case No. 3:15-cv-03783, US District Court for the Northern District of California, citing violations of the company’s disclosure under the California Transparency in Supply Chains Act, and on August 18, 2015, the US Court of Appeals for the District of Columbia Circuit issued a highly anticipated decision in National Association of Manufacturers, et al. v. SEC, et al., No. 135252 related to the Securities and Exchange Commissions’ Conflict Minerals Rule.
We discuss these cases and suggest steps supply chain managers and compliance officers, across all industries, may consider in strengthening global compliance efficiently and effectively.