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California Transparency ActCalifornia Transparency ActCalifornia Transparency Act

Disclosure: Transparency in Supply Chains Act

Beginning in 2012, many companies manufacturing or selling products in the state of California are required to disclose their efforts to eradicate slavery and human trafficking within their direct supply chain. This disclosure is mandated by the California Transparency in Supply Chains Act of 2010 (Senate Bill 657). The law is designed to increase information available regarding manufacturers and retailers efforts (if any) to address slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support. Slavery can take many forms of forced labor, including child labor. Through this disclosure we are communicating our efforts to address the risk of human trafficking and slavery in our direct material supply chain.

Our efforts include:

Risk-based Assessment

We perform an assessment of the materials and countries of origin in our raw material supply chain. The baseline for the assessment is the U.S. Department of Labor's (DoL's) 2010 report listing "goods from countries" that the Bureau of International Labor Affairs has reason to believe are produced by forced labor, child labor or both, in violation of international standards. The risk assessment results indicate we use a small number of materials listed in the DoL report. Through our Supplier Certification (described below), we are working to mitigate the risks for those sourced materials listed in the DoL report.

Supplier Audits

We perform periodic supplier audits on an ongoing basis for validation of material quality and supplier conformance to certain regulatory requirements. All suppliers that certify to our Supplier Code of Conduct may be subject to human trafficking and slavery audits at any time. We do expect that our suppliers be strictly compliant with local laws.

Supplier Certification

We have a Supplier Code of Conduct (Code) which contains specific language regarding human rights and other workplace issues, as well as the right for us to perform human trafficking and slavery audits at any time. Beginning January 1, 2012, we will require our raw material suppliers with materials found on the DoL report to certify to our Code, or provide their own code of conduct that we must review and accept. We may decline to make future purchases from a supplier that does not certify to the Supplier Code of Conduct, or does not provide an acceptable version of their own code.

Internal Accountability Standards

Our employees, contractors and suppliers are expected to adhere to our Human Rights Policy that includes specific provisions related to forced labor, child labor and human trafficking. All employees must also adhere to the guidelines in our Business Conduct Manual, which include disciplinary procedures for any violations.

Procurement Professionals Training

Our employees directly responsible for suppliers are provided awareness training on human trafficking, such as forced labor and child labor, and are expected to report any known or suspected violations.

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