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CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

4Over, LLC. ("ÎÛÎÛ½ûÇø") recognizes the importance of making efforts to ensure that its supply chain is free of any products of forced labor, child labor, human trafficking and/or slavery. In addition to compliance with current U.S. and individual state laws regarding labor practices, ÎÛÎÛ½ûÇø is also required to comply with the California Transparency in Supply chains Act of 2010 (SB657), which requires manufacturers and retailers to disclose their efforts, if any, to track forced labor and human trafficking in their supply chains. The information contained below relates to ÎÛÎÛ½ûÇø’s obligations under this law.

ÎÛÎÛ½ûÇø primarily operates in the United States with one plant located in Toronto Canada. Almost all of ÎÛÎÛ½ûÇø’s products are manufactured in the United States and as such are subject to either U.S. or Canadian laws and regulations regarding among other things forced labor and human trafficking.

Under section 1714.13 of the California Civil Code, manufacturers are requested to post disclosures in five specific categories:

  • Verification of product supply chains to evaluate the potential for products of forced labor, child labor, human trafficking and slavery to be present in its direct supply chain. ÎÛÎÛ½ûÇø does not presently follow a formal policy for verification to evaluate its products;
  • Audits of suppliers to evaluate supplier compliance with company standards for prohibiting trafficking and slavery in supply chains. ÎÛÎÛ½ûÇø conducts informal inspections or observations on occasion but does not presently follow a formal policy for auditing suppliers with respect to supplier compliance however if ÎÛÎÛ½ûÇø became aware of any credible indicator of potential trafficking or forced labor on the part of a direct supplier, ÎÛÎÛ½ûÇø would conduct an unannounced audit;
  • Certification for suppliers in writing that materials incorporated into their products comply with the laws regarding forced labor, child labor, human trafficking and slavery in the country or countries where they do business. ÎÛÎÛ½ûÇø generally requires its contract suppliers to comply with all applicable laws and regulations in the country or countries they do business in but does not presently follow a formal policy for independent certification by suppliers;
  • Maintaining internal accountability standards and procedures for employees or contractors failing to meet company standards regarding avoidance of forced labor, child labor, human trafficking and slavery. 4 does not presently follow a formal policy of internal accountability for employees or contractors; and
  • Providing company employees and management, who have direct responsibility for supply chain management, training on forced labor, child labor, human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products. ÎÛÎÛ½ûÇø does not presently follow a formal policy related to such issues but does require all of its employees to act ethically and comply with all federal and local laws in the conducting of the business of the company.