Slavery and Human Trafficking in Supply Chains Policy and Disclosure

The Pictsweet Company is committed to ethical employment practices in its supply chains. Pictsweet employs only lawful, voluntary labor. Pictsweet employees shall not participate in the furtherance of acts of slavery and human trafficking. Pictsweet’s unambiguous policy is to require that suppliers not employ forced labor of any kind, including that they comply with all applicable laws concerning slavery and human trafficking. In accordance with the requirements of the California Transparency in Supply Chains Act of 2010, Pictsweet discloses the following information:

Verification

Pictsweet engages in verification of product supply chains to evaluate and address various risks, including compliance with the company’s policy prohibiting the use of forced labor of any kind, through site visits and evaluations of certain critical suppliers. Third parties are not used in the verification process.

Audits

Pictsweet conducts scheduled periodic audits through company and third party auditors, of certain critical suppliers for, among other things, ethical labor practices, including compliance with the company’s policy prohibiting the use of forced labor of any kind.

Certification

Pictsweet obligates its direct suppliers by contract to comply with applicable federal, state and local labor laws. This contractual obligation is in essence a certification requirement that any incorporated materials in a product in Pictsweet’s supply chain comply with the forced labor laws in the country of production.

Accountability

Pictsweet prohibits participation by its employees or contractors in the furtherance of acts of slavery and human trafficking. Employees who violate this prohibition are subject to disciplinary action, including termination. Contractors who violate this prohibition will be in default under their contracts, thereby subjecting their contracts to termination.

Training

Pictsweet provides training concerning slavery and human trafficking to company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products.