a Segerdahl company SG360°

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Supply Chains Act

DISCLOSURE OF SG360° PURSUANT TO CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB-657)

The California Transparency in Supply Chains Act requires retailers and manufacturers doing business in California to publicly disclose their efforts to eliminate slavery and human trafficking from their supply chains.

The Segerdahl Corp DBA SG360° has a long-standing commitment to high standards of ethical conduct and compliance with applicable laws. It is our expectation our suppliers also conduct themselves in this manner. We expect our suppliers to obey the laws requiring them to treat their workers in a fair manner and to provide these workers with a healthy and safe work environment.

Verification

SG360° continually evaluates our suppliers on issues of quality, cost and service. SG360° does not have a formal process to verify the risks of human trafficking and slavery within our national supply chain. SG360° is mindful of the geographic regions of the world where such risks are elevated and have determined we are at a low risk for purchasing from vendors engaged in human trafficking or slavery.

Audits

SG360° does not conduct audits of suppliers to evaluate supplier compliance with SG360° standards for trafficking and slavery in supply chains. SG360° retains the right to conduct announced audits on our suppliers in the event such activities are suspected and/or to suspend activity with suppliers, where applicable.

Certifications

Currently, we do not require our direct suppliers to certify they comply with anti-slavery and human trafficking laws in the country or countries in which they do business.

Accountability

Upon hire, SG360° requires all new employees to sign a Statement of Understanding acknowledgement demonstrating they have read, understood and accept as an SG360° employee the SG360° Code of Conduct and SG360° polices. The Code of Conduct includes official recognition the employee will comply with all applicable government laws, rules and regulations. Human trafficking and slavery are violations of such laws and would constitute a violation of the Code of Conduct. Such a violation could result in disciplinary action against the employee.

Training

SG360° does not provide employees or suppliers with training on human trafficking and slavery.