California Transparency in Supply Chains Act

(Cal.Civ.Code § 1714.43)

Tessenderlo Kerley, Inc. (“TKI”) and its parent company, Tessenderlo Group (“TG”), are committed to conducting all business lawfully and with integrity. TKI’s commitment to and expectations for ensuring that our supply chain is maintained in a lawful and socially responsible way includes, among other things, that our suppliers not use forced or slave labor, child labor or any form of human trafficking in any of its forms to produce the products provided to TKI. TKI’s compliance and ethics expectations are set out in the TG’s Code of Conduct, TKI's Supplier Code of Conduct, TG’s policy on Human Rights and Labor Rights, and in training and other communications we provide to our own personnel engaged in supply chain activities, our suppliers and other third parties.

TG’s supplier Code of Conduct explicitly states it “does not permit use of child labor in any form. Business partners have to take all of the necessary preventive measures to ensure that they do not employ anyone below the legal age of employment.”   In addition, “[b]usiness partners will neither use any forced or compulsory labor nor will they engage in human trafficking or slavery practices of any kind.”

SUPPLIER AUDITS

TKI does not have a specific supplier audit program for human trafficking violations; however, it periodically conducts general supplier audits. Supplier audit practices vary; some may be done either internally or via independent, external auditors. The scope of the supplier audits covers TKI ‘s standards and guidelines, as well as broader compliance policies and practices. In the event an audit reveals supplier non-conformance with our standards, guidelines, compliance policies, or practices, depending on the circumstances, we would either require that suppliers establish corrective action plans and report on the implementation of such plans, or we would terminate the relationship with that supplier.

DIRECT SUPPLIER CERTIFICATION

While many of our commercial agreements require supplier compliance with applicable laws and regulations, TKI does not have a direct supplier certification process specifically focused on human trafficking and slavery.  TKI does strive to require that suppliers comply with our Supplier Code of Conduct, and/or third-party compliance standards and sustainability guidelines for suppliers that  prohibit any forced or coerced labor.

ACCOUNTABILITY STANDARDS

Any supplier or employee non-compliance with our standards regarding human trafficking and slavery will result in corrective action, up to and including termination of the relationship, depending on the circumstances.  TKI business representatives would work with suppliers, and employees to resolve any instances of non-compliance. All TG companies, including TKI, promote a Code of Conduct identifying numerous avenues for reporting compliance concerns, including on an anonymous basis (where allowed by law). Such concerns are objectively investigated under the guidance and direction of our compliance or legal departments.  All TG companies, including TKI, prohibit retaliation against anyone who, in good faith, raises a concern.

TRAINING ON HUMAN TRAFFICKING & SLAVERY

Although TKI does not have a comprehensive, mandatory training program focusing specifically on human trafficking and slavery, TKI conducts mandatory training for all employees on its Code of Conduct that specifically addresses its prohibition of child or slave labor by the company and its suppliers.  The training is provided via interactive computer-based training.

VERIFICATION

Other than the steps and practices described above, TKI does not have a separate, comprehensive verification process for evaluating and addressing the risks of human trafficking and slavery.