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California Transparency in Supply Chains Act

Updated: 6/25/15

The California Transparency in Supply Chains Act requires certain retail sellers and manufacturers doing business in California to provide disclosures regarding efforts to eradicate slavery and human trafficking from their supply chains.

Verification: We currently do not engage in verification activities with suppliers to specifically address risks of human trafficking or slavery in our supply chain. We are considering the feasibility of developing such a verification process with suppliers.

Audit: We do not conduct audits of suppliers in evaluating supplier compliance with company standards for human trafficking and slavery in our supply chains.

Certification: Our supply, purchase and tolling agreements generally require suppliers to comply with applicable laws, without specifying laws regarding human trafficking and slavery.

Internal Accountability: Our Code of Business Conduct and Ethics (i) shares our core values on mutual integrity, fairness and respect in all relationships among employees, customers, suppliers and principals, (ii) addresses compliance with this Code, company policies and all applicable legal and ethical requirements and (iii) contains provisions about disciplinary action.

Our Compliance with Law Policy (i) covers directors, officers, employees and company representatives, (ii) addresses conducting business in compliance with applicable laws and (iii) contains provisions about investigating for noncompliance and disciplinary action. Our Code of Business Conduct and Ethics and Compliance with Law Policy do not specifically address human trafficking and slavery.

Training: We provide training on our Compliance with Law Policy to personnel, plant managers and senior management/officers. We currently do not provide specific training on topics of mitigating risks relating to human trafficking and slavery within supply chains of products. We are currently considering training of company employees and management who have direct responsibility for supply chain management with respect to mitigating risks within the supply chains of products.

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