California Transparency in Supply Chains Disclosure (TSC)

As part of our efforts to inform our customers of our efforts to eradicate slavery and human trafficking from our supply chains, we are providing this disclosure regarding how to purchase goods produced by companies like ours that responsibly manage our supply chains, and, thereby, improve the lives of victims of slavery and human trafficking. California's Transparency in Supply Chains Act of 2010 (SB 657) requires certain companies that manufacture or sell products in the State of California to disclose their efforts, if any, to address the issue of slavery and human trafficking in their direct supply chains.

Our company prioritizes ethics, safety, honor and commitment in all aspects of our business. Included in our values are respect for all people, ethics, and operational excellence. To that end, we endeavor to maintain transparency in regard to our supply chain and conduct periodic due diligence to trust but verify that our compliance efforts are adequate and effective.

Key components of our TSC program include the following:

Supplier Verification Practices

• Our company takes steps to verify that our suppliers are not engaging in slavery or human trafficking. This may include, but not be limited to, assuring that our suppliers have policies and procedures in place that are adequate to deter and prevent these issues. In addition, we affirmatively expect our suppliers to conduct regular audits of themselves, and we review those audits, to assure compliance. Should any of our suppliers detect noncompliance with TSC, we expect them to disclose these non-conformities and take prompt corrective action – reauditing to assure they have effectively remedied any instances of noncompliance.

Supplier Certification and Audits

• We require all of our suppliers to certify that they are not engaging in slavery or human trafficking. We expect this certification to be based upon an independent audit of the suppliers’ operations, including any key contractors or subcontractors upon whom they rely in providing services and goods to us and/or on our behalf. All suppliers are expected to report noncompliance issues detected during these audits to us and to take prompt corrective action – reauditing to assure they have effectively remedied any instances of noncompliance.

Internal Accountability Standards and Training

• We have in place internal training and hold our own workforce accountable for assuring compliance with TSC in the United States and globally. We are introducing internal accountability standards and training programs to assure that our workforce is aware of and complies with TSC standards. Among the topics trained are how to identify and report potential instances of slavery or human trafficking in the supply chain. We expect our suppliers to maintain similar accountability standards and training. It is our expectation that any instances of actual or suspected non-conformity with TSC standards are reported immediately and that prompt remedial action be taken.