The California Transparency in Supply Chains Act of 2010 (SB 657)

Litehouse is providing this statement about its obligations under the California Transparency in Supply Chains Act of 2010 – S. B. 657 (the “Act”). The Act requires Litehouse to publically disclose its efforts to eradicate human trafficking from its direct supply chain. Human trafficking is a form of forced and compulsory labor. Litehouse is committed to the elimination of all forms of forced and compulsory labor, including human trafficking, and to the effective abolition of child labor. Litehouse’s Employee Owner’s Conduct and Work Rules, Policy 600, which applies to all Litehouse employee owners, explicitly prohibits Litehouse employee owners from hiring child or forced labor and states that any suspected instances of these abuses, whether in our own operations or those of suppliers, should be reported to our Human Resources department for immediate investigation.

Litehouse expects its suppliers to comply with legal requirements and operate consistently with the principles of Litehouse when working on our behalf. Although Litehouse does not currently have a formal verification program, we do ask our potential suppliers to state and affirm their compliance with the Act when we assess them as new suppliers. Litehouse does not perform social responsibility audits, either internally or through a third-party audit, in relation to the Act at this time. Litehouse employee owners who engage suppliers, vendors, or individual contractors to work on behalf of Litehouse are required to inform them on Litehouse’s commitment to the Act and seek their cooperation in adhering to it. However, Litehouse does not require direct suppliers to certify that materials incorporated into their products comply with slavery and human trafficking laws in the country or countries in which that supplier is doing business. Litehouse maintains internal accountability standards and procedures for employee owners and contractors who fail to comply with the Act and has a policy to investigate reported cases of non-compliance. In maintaining our commitment to comply with the Act, Litehouse will terminate supplier contracts when a serious breach of the Act by a supplier is found to have occurred.

Although not currently in place, Litehouse is working towards providing a training program on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products, to employee owners and management who have direct responsibility for supply chain management.