California Transparency in Supply Chains Act

California’s Transparency in Supply Chains Act of 2010 encourages businesses operating in the state to provide greater insight into how they manage risks related to slavery and human trafficking. The law reflects growing recognition that modern supply networks can involve numerous companies, workers, contractors, manufacturers, and suppliers across multiple countries. Greater visibility can help businesses understand where products and materials come from and identify circumstances that may present human rights concerns.

The Company recognizes the importance of responsible sourcing and supports the broader objectives of California’s supply chain transparency framework. Slavery, forced labor, child labor, and human trafficking are serious violations of fundamental human rights and have no place in legitimate commercial activity. The Company does not permit these practices within its own facilities or operations and does not support their use by organizations involved in producing or supplying goods connected with its business.

Global supply chains can be complicated, with products sometimes passing through several levels of manufacturers, processors, distributors, contractors, labor providers, and other organizations before reaching customers. This structure can make it difficult to maintain complete visibility across every stage of production. The Company understands that responsible supply chain management requires awareness of these challenges and continued attention to the conditions under which goods and materials are produced.

At present, the Company does not maintain a dedicated verification procedure covering every product supply chain specifically for the purpose of identifying slavery or human trafficking risks. The Company therefore does not claim to have a comprehensive trafficking-specific verification system in place. Instead, supplier relationships are managed with consideration for applicable legal requirements, commercial expectations, operational standards, and responsible business practices.

The Company also does not currently operate a specialized supplier auditing program that is designed exclusively to determine compliance with Company requirements concerning slavery or human trafficking. General supplier reviews may address areas such as quality, legal compliance, operational performance, and business requirements, but these activities should not be understood as dedicated human trafficking audits unless a specific program has been established for that purpose.

Similarly, suppliers are not presently required to provide a separate certification confirming compliance with slavery and human trafficking laws in every jurisdiction where they conduct business. Nevertheless, suppliers, manufacturers, contractors, and other commercial partners are expected to follow the laws and regulations applicable to their activities. These expectations include lawful employment practices, appropriate working conditions, workplace safety, employee protections, and compliance with requirements concerning forced or involuntary labor.

The Company does not currently maintain a specific disciplinary framework intended solely to address employee or contractor violations of dedicated slavery and human trafficking standards. Employees, contractors, and business partners are nevertheless expected to follow applicable laws, contractual commitments, internal policies, and ethical requirements. Where misconduct or noncompliance occurs, the matter may be addressed through the relevant employment, contractual, compliance, or business procedures.

Specialized training focused exclusively on slavery and human trafficking is also not currently provided to all employees or management personnel with supply chain responsibilities. The Company recognizes that education and awareness can contribute to identifying potential labor abuses and improving responsible sourcing practices. As regulatory expectations and business needs develop, the Company may consider additional training, communication, or educational resources to strengthen awareness of human rights risks within supply networks.

Responsible sourcing remains an important consideration when establishing and maintaining relationships with suppliers and other business partners. Commercial partners are expected to operate lawfully and responsibly in the countries and regions where they conduct business. They should maintain employment practices that respect workers and avoid conditions involving coercion, exploitation, involuntary labor, or other prohibited forms of employment.

The Company understands that preventing human trafficking cannot depend solely on direct relationships with first-tier suppliers. Risks may exist farther along the supply chain, including among subcontractors, raw material providers, labor agencies, processors, and other organizations that may not have a direct contractual relationship with the Company. Improving awareness of these extended relationships can therefore be an important part of broader efforts to promote responsible production.

The Company remains firmly opposed to child labor, slavery, forced labor, and human trafficking. These practices are inconsistent with the Company’s expectations for lawful and ethical business conduct. Business relationships should be maintained in a manner that respects applicable labor protections and recognizes the importance of safe and fair working environments.

Compliance with applicable laws is also an important part of the Company’s overall approach to business responsibility. The Company seeks to conduct its activities in accordance with relevant federal, state, and local requirements and expects its commercial partners to do the same. Partners whose conduct creates significant legal, ethical, or human rights concerns may be subject to appropriate review or other action consistent with the circumstances.

Supply chain expectations may change as laws, industry standards, and responsible sourcing practices continue to develop. The Company may therefore review its existing practices and consider additional measures where appropriate. Future efforts could include stronger supplier communications, expanded contractual expectations, additional risk assessments, improved supplier information, educational initiatives, or other methods for increasing supply chain awareness.

The absence of a formal program in a particular area should not be interpreted as acceptance of slavery or human trafficking. Rather, this disclosure is intended to provide an accurate description of the Company’s current practices and limitations. The Company supports the principles behind greater supply chain transparency and recognizes the importance of continuing to evaluate how businesses can contribute to the prevention of worker exploitation.

Protecting workers throughout international supply networks is a shared responsibility. Companies, suppliers, manufacturers, governments, employees, industry groups, and other stakeholders all have roles to play in promoting ethical labor practices. The Company will continue to consider these responsibilities as it manages its business relationships and evaluates applicable compliance obligations.

The Company’s position remains clear: slavery, human trafficking, forced labor, and child labor are unacceptable. By maintaining expectations for lawful conduct, recognizing the complexity of global sourcing, and remaining attentive to evolving standards, the Company seeks to support a business environment where workers are treated with dignity and fundamental human rights are respected throughout the supply networks connected with its products.