California Transparency in Supply Chains Act Disclosure
California law requires companies to disclose their efforts to address the issues of slavery and human trafficking in supply chains for tangible goods offered for sale. HBD Industries, Inc. and its subsidiaries (“HBD”) manufacture industrial products. All HBD manufacturing facilities are located in the United States. HBD Industries and its companies maintain a strict Business Ethics and Corporate Compliance Procedure. All employees are required to review and acknowledge the procedure upon hire, and any employees who are involved in purchasing functions are required to certify compliance with applicable requirements on an annual basis. The Business Ethics and Corporate Compliance Procedure requires compliance with applicable laws and regulations, and reporting of suspected violations. Engaging suppliers that do not produce goods in accordance with applicable law is contrary to HBD policy and HBD contract terms. HBD conducts regular assessments of its suppliers. Audits and assessments are not independent or unannounced, and do not include verifications of supply chains to evaluate risks of human trafficking and slavery. HBD terms of purchase require suppliers to adhere to all applicable laws, which would include compliance with all laws pertaining to slavery and human trafficking. HBD’s Business Ethics and Corporate Compliance Procedure contains internal accountability standards and procedures. Employees involved in procurement activities are regularly evaluated and are required to certify, annually, their understanding of and compliance with these standards and procedures. The accountability standards and procedures and employee training do not specifically address slavery and trafficking, and HBD does not require direct suppliers to certify that materials incorporated into their product comply with human trafficking and slavery laws of the country or countries in which they are doing business.
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