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California Transparency in Supply Chains Act of 2010

SNF Inc., and its affiliates are supporters of the California Transparency in Supply Chains Act of 2010 (SB 657). The purpose of the Act is to increase the amount of information available to the public regarding the efforts by manufacturers and retailers to address the issue of slavery and human trafficking in their supply chains.

SNF Inc., and its affiliates take the following efforts to ensure that all individuals within its supply chain are free from slavery and human trafficking.

1. We incorporate the Code of Basic Working Conditions in the terms and conditions portion of all purchase orders, a copy of which is included with all of our purchase orders. Acknowledgment and acceptance of our purchase order shall be deemed to constitute acceptance and verification of supplier’s intention to comply with the Code of Basic Working Conditions. At this time, we do not engage a third party to participate in these verifications.

2. We seek to verify our suppliers’ compliance with our Code of Basic Working Conditions by attempting to incorporate the Code of Basic Working Conditions in all new contracts. At this time, we do not employ an independent, unannounced audit.

3. We request that our direct suppliers certify that all materials provided to SNF by the supplier were manufactured by employees who are not victims of slavery or human trafficking.

4. We require employees of SNF, Inc. and its affiliates, to be familiar with our Code of Basic Working Conditions and to immediately advise our management team in the event that a supplier does not comply with those requirements.

5. We provide training on human trafficking and slavery to all employees who have direct responsibility for supply chain management.