July 31, 2023
Mitsubishi Electric Automation (MEAU) is a leading supplier of factory automation products in North America. We source products internationally and recognize the importance of human rights. We are strictly committed to standards of legal compliance and ethical business conduct as it relates to our procurement of goods and services. We will not partner with any business that uses forced labor. We participate in the execution of forced labor prohibition laws and government policies in our supply chain.
As our foreign supplier, we want you to partner with us to further develop compliance in your supply chains as defined by the processes provided to MEAU by the United States Customs Trade Partnership Against Terrorism. (CTPAT MSC 3.9). We also expect our suppliers to measure these standards against their suppliers and subcontractors by implementing and maintaining mapping of supply chains to identify product making inputs that may contain forced labor. Operations take place in an increasingly diverse universe, so circumstances can arise where legal, regulatory or other requirements may necessitate applying or interpreting this Code in ways that assure compliance with applicable local law.
The forced labor standards are based on Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307).
The Act prohibits the importation into the U.S. of goods made using forced labor. Section 307 prohibits the importation of any goods made “wholly or in part” using forced, indentured, or convict labor, anywhere in the world. “All goods, wares, articles, and merchandise, mined, produced, or manufactured wholly or in part in any foreign country by convict labor or/and forced labor or/and indentured labor under penal sanctions shall not be entitled to entry at ports of the U. S. The importation thereof is prohibited. U.S. Customs agency has the power to issue a Withhold Release Order (WRO), which is an instruction to U.S. Customs Officers to prevent imports from entering the U.S. due to “reasonable but not conclusive” evidence that forced labor was used in the overseas production of the goods. Goods that are subject to a WRO will be detained at U.S. ports.
Forced Labor is defined by the International Labor Organization’s Convention No. 29. It applies to all work or service exacted from any person under the menace of any penalty for its nonperformance and for which the worker does not offer himself voluntarily. The International Labor Organization Convention has eleven indicators of forced labor. They are deception, isolation, physical and sexual violence, restriction of movement, abuse of vulnerability, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions and excessive overtime. Section 307 also prohibits indentured labor which refers to debt bondage and peonage. The term “forced labor or/and indentured labor” includes forced or indentured child labor. It prohibits the importation of goods made using overseas convict or prison labor without exceptions.
MEAU treats foreign suppliers with respect and integrity and is dedicated to serving as a good partner to you who help us meet our mission. You are expected to protect internationally proclaimed human rights in your operations and for your employees, and do not directly or indirectly use forced labor, or inputs produced using such labor. MEAU provides you with training to check your suppliers’ risk of being involved in forced labor. In turn, you will provide MEAU with evidence of supply chain mapping of your suppliers. Together MEAU and you will contribute to making our supply chains free of forced labor risk.