California Transparency in Supply Chains Act Disclosure Statement
A new law in effect in California as of January 1, 2012, known as the Transparency in Supply Chains Act (the "Act"), requires manylarge retailers and manufacturers doing business in California to disclose publicly their efforts to eradicate slavery, human trafficking and child labor from their supply chains. One objective ofthe law is to provide consumers with information that will enable them to make informed purchasing decisions.
Lactalis American Group, Inc. and Subsidiaries are dedicated to conducting businessin a lawful and ethical manner. We also expect our suppliers to conduct themselves in an ethical manner. Please be advised that we comply with the laws regarding slavery and humantrafficking in the countries in which we are doing business and require our direct suppliers to certify that they also are compliant. Our efforts to ensure and verify the absence of such unethical labor practices in our supply chain include the following:
Supplier Contracts: Our supplier contracts require compliance with labor and immigration laws, and we fully expect oursuppliers to comply with all applicable laws. Moving forward, all of our contracts also will expressly require compliance with the Act from and after January 1, 2012. A single violation oflabor or immigration laws may provide sufficient grounds to terminate a supply contract.
Supplier Communication: We require each of our direct suppliers to certify in writing that all supplied goods and materials incorporated into product comply with all laws regarding slavery, human trafficking and child labor. Audits: We may conduct announced audits and/or inspections of oursuppliers upon adequate notice to verify conformance with quality and performance metrics.
Supplier and Employee Education: We are developing a Supplier Code of Conduct to educate suppliersfurther about our expectations and requirements for strong supplier and factory compliance programs. For our employees involved in the procurement of goods and services, we are updating our trainingmaterials to include the Act and instructions on how to identify potential areas of concern in our supply chains.
We will continue to update our policies and procedures to ensure we maintain thehighest standards of conduct throughout our supply chain.