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California Transparency Act


(1)Verification of product supply chains to evaluate and address risks of human trafficking and slavery.

ASO, LLC (“ASO”) on behalf of itself and its affiliated companies has distributed to its suppliers the ASO Social Compliance Policy (“ASCP”) and is requiring all suppliers to acknowledge their receipt of the policy and agree to perform in accordance with its terms. Human trafficking and any form of slavery are dealt specifically with in the ASCP, as well as other social accountability issues. ASO has worked with a consultant in developing its approach to verifying and evaluating supply chain risks of human trafficking and slavery.

(2) Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.

ASCP has an integrated, risk based audit program which is applicable to all suppliers. The program involves both self-audit and third party audits for every supplier. The intensity and frequency of the third party audits vary based on geographical risk evaluations and, as experience is gained, on the historical audit performance of a given supplier. For suppliers in higher risk geographies, independent, unannounced third-party audits by internationally recognized audit firms will be utilized in addition to any audits that may be conducted by ASO personnel. ASO reserves the right to accept a supplier’s social compliance certification obtained from an accredited agency in lieu of an audit.

(3) Certification by direct suppliers that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

All ASO suppliers are required to sign the ASCP which by its terms requires suppliers certify that they will comply with all applicable laws (which include those laws regarding slavery and human trafficking). Further, ASO is in the process of incorporating the ASCP into all of its agreements for the purchase of products and services.

(4) Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

With regard to any issues identified in compliance audits, a formal corrective action plan is developed with specific timeframes in which to correct the problems. Depending of the severity of the negative audit finding re-audits may be required in as short of time as three months. For certain audit findings, such as use of child labor, involuntary or prison labor, physical or sexual abuse, coercion and harassment, severe health and safety violations, or denial of access of facilities to auditor there is a zero tolerance level, and business with the supplier will be promptly terminated and the supplier removed from the approved supplier list for a minimum of one year. Any contractor or employee that fails to meet the standards set out in ASCP will be subject to discipline which includes for a contractor up to and including termination of commercial relationship or for an employee, termination of employment.

(5) Training to company employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

ASO has established a training program for all senior executives and employees who have interaction with supply chain matters. ASO believes it is fundamental for all these relevant individuals to be aware of the requirements set out the ASCP and to be aware of the actions that can be taken to mitigate risks associated with such critical issues as forced labor, slavery, human trafficking and child labor.

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