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Supply Chains Act 2010

DISCLOSURE REQUIRED PURSUANT TO THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

The ϲͼ Company is committed to working with suppliers who do not engage in human trafficking and forced labor. Accordingly, The ϲͼ Company has established the following guidelines when dealing with potential suppliers.

  1. Verification – The ϲͼ Company may, at its discretion, perform preliminary risk assessments for slavery and human trafficking of suppliers according to a risk based approach based on any suspected or known risks, and country location.
  2. Auditing – If The ϲͼ Company should identify any suppliers at high risk for slavery or human trafficking, The ϲͼ Company will consider appropriate actions to take with respect to such supplier. Such actions may include an on-site audit to determine if such suppliers are engaging in any slavery or human trafficking. The ϲͼ Company will determine at the time of such audit whether the audit will be unannounced, and will be conducted by The ϲͼ Company, or its designee or an independent third party.
  3. Certification – The ϲͼ Company’s commitment to ensuring that its supply chain is maintained in a socially responsible way includes, among other things, an expectation that direct suppliers not engage in human trafficking and slavery to produce the products they provide to The ϲͼ Company. To monitor compliance with its expectations, The ϲͼ Company encourages suppliers to sign a written certification that they will comply with applicable laws regarding slavery and human trafficking in connection with the production of products they supply to The ϲͼ Company.
  4. Internal Accountability – All employees and contractors of The ϲͼ Company are expected to comply with all laws, including laws addressing slavery and human trafficking. Failure to adhere to the applicable laws may result in disciplinary action up to and including discharge and termination by The ϲͼ Company.
  5. Procurement Training – The ϲͼ Company is currently reviewing various training materials which include mitigation of risks of slavery and human trafficking within the supply chain. The ϲͼ Company intends to make such materials available to employees who are responsible for supply chain management.