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TRANSPARENCY

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

We are committed to fair labor practices within our supply chain. We, therefore, provide our suppliers with a Supplier Excellence Manual to identify and evaluate the potential risks for human trafficking and slavery and with which we expect them to comply.

As a part of our vetting process, we require each vendor to adhere to our Code of Conduct and company’s standards for trafficking and slavery in supply chains, compliance with applicable local and international labor laws, and management policies. To ensure that our contractors and suppliers respect and enforce our company standards, we include a clause in our commercial Terms & Conditions governing our contractual relationship with them which stipulates that they must abide by our anti-slavery and human trafficking standards.

We will not tolerate the involvement of our suppliers in human trafficking and/or slavery. Although we do not maintain a formal verification, audit or certification process with respect to our suppliers’ compliance with laws specifically related to human trafficking and slavery, we will quickly investigate any reports alleging human trafficking and slavery in our supply chain, and we will take action against any supplier we find to have acted improperly in this regard.

Our company is committed to respecting the human rights of our employees. Our Code of Ethics and company policies adhere to the principles of free choice of employment, nondiscrimination, and humane treatment. We ensure compliance with applicable regulations governing child labor, minimum wage, and maximum working hour limitations.

All new employees go through a training program including awareness of all company policies including, but not limited to, code of conduct, cyber security, whistleblower policy, and policies against human trafficking and slavery.

Non-compliance with our company policies can result in corrective action or termination, depending on the number of non-compliances found and their severity. Our management works with employees to develop action plans to resolve any such instance of non-compliance. If and when our company uncovers employee compliance problems, we provide written notice and a period of time for corrective action. While we believe in sustainable remediation, we reserve the right to terminate a business relationship with an employee if it is deemed necessary.

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