The California Transparency in Supply Chains Act of 2010 (SB 657) requires certain companies that manufacture or sell products in the State of California to provide information regarding their efforts, if any, to eradicate slavery and human trafficking in their direct supply chains. Jandy Brands Inc, its subsidiaries and affiliates (“KOCOSTAR USA”) support the principles of this law and are committed to conducting all business activities in accordance with the highest ethical standards. KOCOSTAR USA has long had a code of conduct with which its employees are expected to follow. This disclosure describes the additional steps KOCOSTAR USA intends to take to address human trafficking and slavery in its supply chains.

Certification: KOCOSTAR USA will be instituting a program to request any new suppliers to confirm their compliance with legal and company standards, under which such suppliers must  certify that materials incorporated in their products comply with laws regarding slavery and human trafficking of the countries in which they do business.   Similar requests will be made over time to existing suppliers as they renew their agreements with KOCOSTAR USA. Responses to such requests will be evaluated on an case-by-case basis, and further action taken as appropriate.

Training: KOCOSTAR USA plans to provide training on human trafficking and slavery to employees and management with direct responsibility for supply chain management.

Internal Accountability: KOCOSTAR USA will be updating its internal code of conduct to specifically address the responsibility of employees and contractors to comply with company standards regarding human trafficking and slavery.

Verification and Audit:  At this time, due to the volume of suppliers, KOCOSTAR USA does not currently have specific processes or use third parties for verification of its product supply chains to evaluate and address human trafficking and does not conduct audits of suppliers to evaluate compliance with company standards regarding trafficking and slavery.  However, it will continue to evaluate the compliance program that it has instituted and consider adding these features to the extent necessary to address any concerns with non-compliance and will update this disclosure accordingly.