California Transparency in Supply Chains Act

California has established the California Transparency in Supply Chains Act of 2010 to encourage greater disclosure and awareness regarding the measures businesses may use to address slavery and human trafficking within their supply networks. The legislation reflects a broader effort to improve visibility into international sourcing and production activities and to encourage qualifying retailers and manufacturers to consider the human rights risks that may arise throughout their commercial relationships. Businesses covered by the law are expected to describe the extent to which they have adopted practices intended to evaluate, prevent, and respond to concerns involving forced labor, trafficking, and related forms of worker exploitation.

Modern supply networks can involve numerous participants operating across multiple jurisdictions. Depending on the nature of a product, its materials may move through manufacturers, processors, contractors, distributors, labor providers, suppliers, and other intermediaries before reaching the final customer. This complexity can make it difficult to maintain complete visibility into every stage of production. Responsible supply chain management therefore requires businesses to remain aware of where products and materials originate and to consider the potential risks associated with limited transparency. Slavery, forced labor, and human trafficking may be more difficult to identify when sourcing arrangements involve several layers of third parties, making responsible commercial practices an important component of ethical business operations.

The Company acknowledges the importance of the principles reflected in California’s supply chain transparency requirements and supports the broader objective of reducing and ultimately eliminating slavery, involuntary labor, and human trafficking from commercial supply networks. At the present time, however, the Company does not maintain every individual policy, procedure, or formal practice described or contemplated by the Act. This statement is provided to communicate the Company’s current position accurately and transparently and is not intended to suggest that specialized programs or controls have been established where they do not presently exist.

The Company does not currently operate a dedicated verification system designed to examine every product-related supply chain specifically for slavery or human trafficking risks. Nevertheless, the Company considers responsible sourcing and appropriate business conduct when developing and maintaining relationships with suppliers, manufacturers, vendors, contractors, and other commercial partners. Business partners are expected to comply with applicable laws and regulations and to conduct their operations in a manner consistent with lawful employment practices, responsible sourcing principles, and appropriate standards of business integrity.

At this time, the Company does not maintain a specialized supplier auditing program whose sole purpose is to determine compliance with Company-specific requirements addressing slavery and human trafficking. Supplier relationships may involve broader commercial expectations relating to product quality, operational performance, legal compliance, contractual obligations, or other business considerations. These general activities should not be understood as a dedicated human trafficking audit unless a specific program has been formally established for that purpose. The Company nevertheless recognizes that appropriate supplier oversight and improved knowledge of sourcing arrangements can support efforts to reduce the possibility of abusive labor conditions.

The Company does not currently require all suppliers to submit a separate written certification confirming that every material used in its products complies with slavery and human trafficking laws in each jurisdiction where the supplier operates. Suppliers are, however, expected to follow the laws and regulations applicable to their businesses, including requirements related to employment, workplace conditions, sourcing, manufacturing, compensation, and worker protections. Compliance with applicable legal requirements and adherence to responsible business standards are regarded as important elements of sustainable and trustworthy commercial relationships.

The Company also does not currently operate a dedicated employee accountability program specifically intended to impose discipline for failing to meet Company standards focused exclusively on slavery or human trafficking. Employees, contractors, suppliers, and other business partners are nevertheless expected to act in accordance with applicable law, Company requirements, contractual commitments, and appropriate ethical standards. Where conduct conflicts with established policies, contractual responsibilities, or legal requirements, the matter may be handled through applicable internal procedures or contractual remedies.

Specialized training devoted exclusively to slavery and human trafficking is not currently provided to every employee or management representative who may have responsibilities involving supply chain activities. The Company understands, however, that awareness and education can help organizations recognize potential warning signs, understand relevant responsibilities, and strengthen responsible sourcing practices. As regulatory requirements, industry expectations, and business operations develop, the Company may assess whether additional training materials, guidance, procedures, or internal controls would be appropriate for improving awareness and supporting effective supply chain oversight.

The Company firmly supports the underlying principles of the California Transparency in Supply Chains Act and considers slavery and human trafficking to be unacceptable violations of fundamental human rights. There is no legitimate business purpose for permitting exploitation, coercion, or involuntary labor. The Company does not permit child labor, forced labor, involuntary employment, slavery, or human trafficking within its own facilities or operations, and it does not support the use of such practices by parties involved in the supply chains connected to its products.

Suppliers, manufacturers, contractors, and other business partners are expected to operate in compliance with applicable labor and employment requirements in the countries, states, and jurisdictions where they conduct business. These expectations include observing applicable minimum-age requirements, prohibitions against forced or involuntary labor, lawful compensation requirements, workplace health and safety obligations, and other protections established for workers. Commercial partners are expected to maintain employment practices that are lawful, responsible, and consistent with recognized principles of fair treatment.

The Company recognizes that direct supplier relationships represent only one part of a broader supply network. Products and materials can move through several levels of production and distribution, including raw-material providers, processors, manufacturers, subcontractors, labor agencies, logistics providers, wholesalers, and other intermediaries. Risks associated with worker exploitation may therefore exist beyond the immediate business relationship. Addressing these risks requires continued attention throughout the commercial ecosystem and cooperation among businesses and other stakeholders. The Company supports reasonable efforts to improve awareness of these challenges and encourages responsible conduct among parties involved in producing, handling, and distributing its products.

Responsible business practices form an important part of the Company’s overall approach to legal and ethical compliance. The Company seeks to conduct its operations in accordance with applicable federal, state, and local requirements, together with other laws and standards relevant to its activities. Similar expectations apply to business partners, who are expected to maintain appropriate levels of integrity and to avoid practices that could create material legal, ethical, labor, or human rights concerns.

The Company further recognizes that expectations surrounding supply chain transparency and human rights can change as legislation, regulatory guidance, industry standards, and public awareness develop. For that reason, the Company may periodically evaluate its existing policies, supplier relationships, and compliance practices to determine whether additional measures would be appropriate. Depending on future circumstances, potential enhancements could include more detailed supplier communications, stronger contractual provisions, additional risk-based assessments, expanded verification procedures, educational programs, or other initiatives intended to improve transparency and reduce potential exposure to harmful labor practices.

Any future measures would be considered in light of the Company’s operations, applicable legal obligations, available resources, and the nature of its supply relationships. The Company understands that effective responsible sourcing is an ongoing process rather than a single action. Maintaining awareness of supplier relationships, evaluating emerging risks, communicating expectations, and reviewing business practices can contribute to a stronger framework for responsible supply chain management.

This disclosure is intended to provide an accurate description of the Company’s present approach to the matters addressed by California’s supply chain transparency framework. The fact that the Company has not adopted a particular formal program should not be interpreted to mean that the Company considers slavery, forced labor, or human trafficking acceptable or unimportant. To the contrary, the Company remains opposed to worker exploitation and recognizes the importance of promoting lawful and ethical conditions throughout the commercial networks associated with its products.

Protecting individuals from exploitation is a responsibility shared by businesses, suppliers, manufacturers, contractors, governments, industry groups, workers, customers, and other participants in the global marketplace. No single organization can address every supply chain risk independently, particularly where production and sourcing arrangements cross numerous jurisdictions and involve multiple levels of third-party participation. Continued awareness, responsible decision-making, lawful conduct, and appropriate cooperation can help strengthen efforts to protect workers and promote more transparent commercial practices.

The Company will continue to consider its legal responsibilities, business relationships, and evolving expectations concerning responsible sourcing and supply chain transparency. Where appropriate, it may review existing practices and evaluate opportunities to strengthen its approach. The Company remains committed to conducting business with integrity and to supporting lawful, responsible treatment of workers. Child labor, forced labor, slavery, human trafficking, and other forms of involuntary or exploitative labor are not acceptable within the Company’s facilities, operations, or the supply networks connected with its products.