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California Supply Chain Transparency (CSC) Act

Nice-Pak and PDI have a longstanding commitment to excellence in product innovation, quality, customer service, customer and consumer education. We believe in responsible, sustainable business practices that benefit our business, our associates, our communities, and society for generations to come. We hold our vendors and suppliers to the highest ethical standards.

Nice Pak and PDI are committed to compliance with all applicable regulations and ethical sourcing of our materials. Nice-Pak and PDI do not practice, condone, or knowingly source from suppliers involved in slave trade/ human trafficking. Each one of our manufacturing sites is subject to multiple third-party accredited social/ ethical audits annually, which verify our compliant status.

1. Verification. At a minimum, disclose to what extent, if any, that the retail seller or manufacturer engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

NicePak and PDI uses a variety of internal methods to verify its suppliers generally, including site audits and visits. Before we work with a supplier, NicePak and PDI supplier questionnaires require suppliers to certify compliance with applicable laws and regulations including laws related to recruitment and remuneration, forced or child labor, human trafficking and social security and welfare.

2. Audits. At a minimum, disclose to what extent, if any, that the retail seller or manufacturer conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

We audit suppliers initially and, on an established frequency based on risk. These audits are announced and conducted by NP/PDI or an independent auditor.

3. Certification. At a minimum, disclose to what extent, if any, that the retail seller or manufacturer requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

As a condition of qualification, we require our suppliers certify they do not rely upon or promote the manufacturer, production, and packaging of materials or products, any child labor, forced or compulsory labor or human trafficking and to comply with all laws, rule and regulations related to child labor, forced or compulsory labor or human trafficking.

Nice Pak is beginning to use third-party certification standards, including Roundtable on Sustainable Palm Oil (RSPO) and Forest Stewardship Council (FSC), that provide third-party certification that some of the key raw materials we purchase are produced without the use of forced labor.

4. Internal Accountability. At a minimum, disclose to what extent, if any, that the retail seller or manufacturer maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

We are committed to conducting business according to the highest principles of business ethics. We have earned an excellent reputation for operating with honesty and integrity, and in full compliance with the laws and regulations of the states and countries in which we do business. Nice-Pak Products, Inc. and PDI, Inc. (together, the “Company”) are committed to conducting business according to the highest principles of business ethics. Our Code of Business Ethics and Conduct (this “Code”) sets out the high business standards as part of our long-standing commitment to fair and ethical dealings with our customers, business partners, competitors, government agencies, and each other. All associates, are expected to read, understand and comply with this Code. Failure to follow this Code can result in disciplinary action, up to and including termination.

5. Training. At a minimum, disclose to what extent, if any, that the retail seller or manufacturer provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

All employees are required to read the Code of Business Ethics and Conduct (this “Code”)Code of NicePak/PDI does not provide specific training to its employees or suppliers regarding human trafficking or slavery.