California Supply Chains Act

“CALIFORNIA SUPPLY CHAINS ACT”

Hy Cite Enterprises, LLC, a Wisconsin limited liability company (“Hy Cite”), is committed to performing to the highest ethical standards in every part of our business. Accordingly, we support the goals of the California Supply Chains Act of 2010 (the “Supply Chains Act”) and have developed an internal policy designed to ensure that our manufacturers and suppliers adhere to the same ethical standards that we work diligently to uphold.

Verification and Audit

Before we collaborate with any new product suppliers, our internal team conducts a multi-layer assessment of each prospective product supplier. In our initial assessment, our team conducts on-site visits of the manufacturing facility or headquarters of each prospective product supplier. During these on-site visits our internal assessment team observes the working conditions of the employees of each prospective product supplier. The team looks for common signs of human trafficking and slavery at the prospective product supplier’s manufacturing facility and engages in discussions regarding the labor standards, practices, policies and working conditions of the employees of said prospective product supplier. If, among other requirements, the prospective product supplier passes the internal supplier thresholds established by us, including, but not limited to the labor and human rights standards that we require our product suppliers to abide by, we enter into Product Supply Agreements with said product supplier.

Every year thereafter, an internal team of Hy Cite employees conducts announced audits of a portion of our product suppliers. During these audits we inspect the labor conditions of the employees and manufacturing facilities of our product suppliers to determine if said product supplier meets the minimum standards that we require with respect to slavery and human trafficking in the supply chain. Furthermore, and in connection with the audit rights described on this webpage, we inspect the books and records of our product suppliers, solely as it pertains to compliance with the Supply Chains Act.

Certification

In addition to conducting periodic audits of our product suppliers, we require our product suppliers to certify compliance with all applicable laws regarding the product supplier’s operations both in their country of origin/operations and the United States. Such certification requirement is accomplished through contractual language contained in our standard form of Supplier Agreement. Given the various employment, labor, intellectual property, and other laws that our product suppliers are required to comply with, we elected to include a broad contractual provision which encompasses the goals of the Supply Chains Act. More specifically, the contractual information in our standard form of Supplier Agreement states:

Compliance with all Laws - Supplier represents, warrants and agrees that the Products provided to Buyer hereunder will comply with all applicable laws, statutes, rules, regulations, or orders, including those related to safety, health, import, export, environmental and employee matters, and taxes. Supplier will procure and maintain all rights, licenses, permits and authorizations that are necessary to its performance hereunder. Supplier will direct and complete all activities under this Agreement, including the delivery of the Product in a safe, useful and workmanlike manner.

Internal Accountability

Members of the Hy Cite product team receive annual training on the Hy Cite ethics policy. Although the details of such training vary from year to year, these training sessions typically include Hy Cite’s Code of Ethics, Hy Cite Policies and Procedures separately, and, on a periodic basis, the provisions included in each standard form of Supplier Agreement.

Using this knowledge, members of the Hy Cite product team are encouraged to (1) have open lines of communication with the management teams of each of our product suppliers, and, as much as possible, their respective work forces and (2) monitor each product supplier to ensure compliance with our established ethical standards.

Any Hy Cite employee that, through an intentional act or omission as determined by Hy Cite, (1) fails to report known violations or (2) is complicit in the commission of such violation will be disciplined by Hy Cite, which may result in the termination of said individual’s employment relationship.