TERMS & CONDITIONS

The California Transparency in Supply Chains Act of 2010 Disclosure
The California Transparency in Supply Chains Act requires that beginning January 1, 2012, retail sellers and manufacturers with annual worldwide gross receipts over $100 million doing business in the state disclose their efforts to eradicate human slavery and trafficking from their direct supply chains for tangible goods offered for sale. The Act requires that the information be posted on the company’s website, with a conspicuous link on the company’s homepage.

The company must disclose its specific actions in relation to five key points, as described in the Act:

Training: Do you train your employees directly responsible for supply chain management on mitigating the risk of slavery and human trafficking in your supply chain?

We do conduct such training. Employees directly responsible for procurement and supply chain management are trained on such issues as forced labor and child labor.

Certification: Do you require your direct suppliers to certify that the materials incorporated into your product comply with the local laws on slavery and human trafficking?

We do require that our suppliers certify that they comply with those laws of the country in which they operate relating to child labor and forced labor / slavery. We have an ongoing program requiring written agreement from all our direct suppliers to comply with applicable laws and regulations regarding forced labor and child labor.

Verification: Do you engage in third-party verification; have you identified the risk of slavery and human trafficking in your supply chain?

We do not yet engage in 3rd party verification.

Auditing: Do you engage in independent, unannounced auditing to check on adherence to your company standards on slavery and human trafficking?

We do not at this time engage in such independent, unannounced auditing. However, we intend to review our practices in this regard and explore the use of third-party auditors at least with respect to any suppliers operating in high risk territories.

Internal accountability: Are you holding your employees and contractors accountable to your company standards on slavery and human trafficking?

We do have internal standards embodied in our corporate code of conduct and violations of such code can lead to disciplinary action.