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The Garland Company, Inc.

California Supply Chains Act

The California Transparency in Supply Chains Act of 2010 (the "Act") was approved by the Governor of California on September 30, 2010. The Act requires that manufacturers and retailers doing business in the state of California disclose efforts to eradicate slavery, underage labor, and human trafficking from the direct supply chain.

In compliance with the Act, Garland Industries, Inc. and its affiliated companies ("Garland") state that Garland is committed to ensuring that slavery, underage labor, and human trafficking do not exist in Garland's supply chain. Garland requires that its suppliers comply with all applicable laws including, but not limited to, laws prohibiting slavery, underage labor, and human trafficking. As Garland believes there is low risk in its supply chain for noncompliance, Garland does not currently audit its suppliers for compliance. However, Garland will consider additional measures, such as auditing suppliers, if Garland determines that any suppliers are at high risk for noncompliance. If Garland suspects a supplier is involved in slavery, underage labor, or human trafficking, Garland will order an investigation. If Garland uncovers compliance problems, Garland will provide such supplier with written notice and a specified period of time to take corrective action. In addition, Garland reserves the right to mandate that a supplier certify compliance with all such laws prior to continuing a relationship with such supplier.

Garland's employees are required to comply with all applicable laws including, but not limited to, laws regarding slavery, underage labor, and human trafficking. Garland also trains employees, that work within the Garland supply chain, on compliance with applicable laws prohibiting slavery, underage labor, and human trafficking.