Supply Chain Transparency 

The California Transparency in Supply Chains Act of 2010 now requires that companies manufacturing or selling products in the State of California disclose the scope of their efforts to eradicate slavery and human trafficking from its direct supply chain for goods offered for sale. Our Code of Basic Working Conditions expressly forbids the use of illegal child labor and forced labor, regardless of its form (e.g.,slavery and human trafficking). Moreover, slavery and human trafficking are crimes under state, federal and international law.

In support of California’s effort to identify and eliminate slavery and human trafficking from supply chains, we as a company have initiated or will initiate programs in the following ways to help ensure that no slavery or human trafficking exists within our direct supply chain:

1. We request our significant suppliers to provide information on their operations so that we may evaluate and address the risk of slavery and human trafficking. These suppliers in aggregate represent approximately eighty percent of our supply chain expenditures.

2. Although, based on current information, our supply chain is unlikely to incorporate slavery or human trafficking, if serious risks are identified, we will conduct audits and/or retain third-party investigators.

3. As we place new orders, our purchase orders require our suppliers to affirmatively represent and warrant that it is in compliance with applicable laws prohibiting slavery and human trafficking.

4. Our company policies require our employees to operate in accordance with the law and to report any violation of laws by our suppliers and others of which they become aware. Accordingly, we have internal accountability standards and procedures in place in the event of any instances of slavery or human trafficking.

5. Supply Chain employees are trained with regard to the California Transparency in Supply Chains Act of 2010, including mitigation of risks of slavery and human trafficking within the direct supply chain.

Through our efforts and those of our suppliers, we strive to enable responsible purchasing decisions throughout the supply chain as we work together to eradicate slavery and human trafficking. December 21, 2011

December 21, 2011