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CA Transparency in Supply Chain

HD Buttercup strives to maintain an ethical work environment that promotes dignity and respect, and is committed to positive labor and environmental practices in its own facilities and at the facilities of its suppliers. The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California, like HD Buttercup, to disclose their efforts to eradicate slavery and human trafficking from their direct supply chain to tangible goods offered for sale. HD Buttercup makes the following disclosures, as required by the Act and, with respect to its efforts to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale, and confirms that HD Buttercup employs the following practices:

Verification

HD Buttercup’s policies and standards dictate that its suppliers refrain from the direct or indirect use of forced labor and any form of human trafficking. Suppliers are required to certify that they comply with HD Buttercup’s policies and standards.

Auditing

Suppliers are required to demonstrate adherence to HD Buttercup’s policies and standards prohibiting the use of forced labor and human trafficking by permitting social and environmental audits. These audits are conducted by HD Buttercup’s employees and independent third-party audit firms.

Certification

HD Buttercup requires that its suppliers agree to a Vendor’s Agreement which, among other things, requires them to comply with all applicable laws and regulations, provide a safe and sanitary workplace free from harassment and discrimination, and certify that materials incorporated into the products they supply to HD Buttercup do not come from, and that they do not and will not knowingly engage in, any forced labor, slavery or human trafficking. The Vendor's Agreement is intended to make it clear that HD Buttercup does not intend to do business with suppliers that are engaged in slavery and human trafficking.

Internal Accountability

HD Buttercup requires its employees to represent it, and to act at all times, in an ethical manner. HD Buttercup seeks to create and maintain internal accountability standards and procedures for employees and contractors regarding slavery and human trafficking and to make it clear that HD Buttercup does not engage in and does not intend to do business with suppliers that are engaged in slavery and human trafficking. As part of these standards and procedures, HD Buttercup will advise its employees and contractors to bring any suspected supplier issues involving slavery and human trafficking to the attention of HD Buttercup’s management. Possible violations of HD Buttercup’s policy against slavery and human trafficking will be investigated and appropriate action taken, including possible termination of a violator’s relationship with HD Buttercup.

Training

HD Buttercup will provide periodic training for its employees and officers who have responsibility for supply chain management. This training will provide information concerning human trafficking and slavery, familiarize them with identifying slavery and human trafficking issues and address mitigating the risk of such issues within its supply chain of products.