What happened?

On September 22, 2024, Governor Newsom signed AB 3234, which amends Part 4 of Division 2 of the Labor Code, imposing more transparency requirements for employers that audit their child labor practices.

What are the details?

Quick Bites for Employers:

• Employers must provide a clear and conspicuous link to a report detailing the findings of their most recent child labor social compliance audit.
  • This report should include whether the business engages in or supports the use of child labor and any written policies and procedures regarding child employees.

• Defines the term “social compliance audit” to mean an inspection of any production house, factory, farm, or packaging facility of a business to verify whether it complies with social and ethical responsibilities, health and safety regulations, and labor laws, including those regarding child labor.
  • Changes child labor social compliance audit to social compliance audit
  • Eliminates the definition of “Child Labor social compliance audit,” as well as any reference to “child labor,” and replaces it with the definition of a social compliance audit.

Business Considerations

• Employers should update their policies, practices, and procedures to adjust them to the new requirements, especially the link to post the report findings in the manner and form stipulated by the law.

Source References

• CA AB 3234
• California Legislation Requires More Transparency from Employers Utilizing Child Labor (CDF Labor Law LLP) 
• Another New California Corporate Social Responsibility Disclosure Requirement on the Horizon (Ropes & Gray LLP.)
• Assembly Bill 3234: New Requirements for Employers Conducting Social Compliance Audits (Jackson Lewis P.C.)

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