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CA Disclosure Statement

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURE STATEMENT

SIERRA INTERNATIONAL LLC, as a manufacturer doing business in California, and as part of the SIERRA Group (herein collectively “SIERRA”), has programs to effectively manage the risks of slavery and human trafficking throughout its supply chain.

First, SIERRA has in place a global Code of Conduct which addresses business practices of our thirdparty suppliers. All SIERRA suppliers by policy are required to comply with the SIERRA Code of Conduct, and that Code contains specific provisions addressing human rights, labor and business conduct.

Second, SIERRA supports and respects the following international guidelines, which include stances against slavery and human trafficking relative to business practices and labor relations:

The United Nations Declaration on Human rights

International Labour Organization Declaration on Fundamental Principals and Rights at Work o United Nations Global Compact

OECD’s Guidelines for Multinational Enterprises

UN Guiding Principles for Business and Human rights

UN Convention on Rights of Children and Children’s Rights and Business Principles
Third, SIERRA, in furtherance of the above policies as they pertain to SIERRA’s supply chain, requires all of its primary suppliers to agree to submit to an audit by SIERRA which, among other things, specifically addresses that no child labor, or forced or bonded labor, or prison labor, is being utilized by the supplier; all SIERRA suppliers are also required to complete a self-assessment which contains certifications of same.

Fourth, as part of SIERRA’s supplier contract policy, SIERRA requires each supplier to represent, as a condition of contract that “(i) it is not aware that such sources are in any way engaged in human trafficking and slavery; (ii) it will, if asked by SIERRA, request its sources to confirm same are in compliance with standards for preventing human trafficking and slavery; (iii) that materials incorporated into Supplier’s products are believed to comply with laws regarding human trafficking and slavery; and (iv) Supplier will train its own procurement staff if necessary in order to mitigate risks of purchasing from companies which may be in violation of laws regarding human trafficking and slavery.”

Finally, SIERRA institutes training of its procurement personnel, as necessary, regarding its supplier audit and self-assessment requirements. SIERRA will not contract with suppliers in violation of the human rights provisions of its policies.

July 31, 2015