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California Transparency in Supply Chains Act of 2010

American Polymers Corp., dba "Polycoat Products" ("Polycoat") is committed to responsible sourcing and specifically the eradication of human trafficking and slavery in our supply chain. Polycoat follows the principles of the United Nations Global Compact, and in turn we expect our direct suppliers of Polycoat's tangible goods for sale ("Supplier" or "Suppliers") to adopt sound human rights practices, to treat workers fairly, with dignity and respect, and in all cases to eliminate human trafficking and slavery in their workplaces.

Verification: Starting in 2016, Polycoat introduced a supplier qualification process for new Suppliers, which "constitutes an essential element of Polycoat's vendor qualification." This process requires all new Polycoat Suppliers to sign Polycoat's Supplier Code of Conduct as a part of Polycoat's initial supplier qualification process, and existing Suppliers, if they have not already done so, to sign Polycoat's Supplier Code of Conduct upon contract renewal. Suppliers must also complete a self-assessment questionnaire designed to ensure compliance with international labor standards regarding, among other things, human trafficking and slavery. Polycoat's Supplier Code of Conduct requires Suppliers to certify that they "operate in full compliance with all laws, regulations and international standards," including but not limited to those relating to social and working conditions which require Suppliers to "respect the provisions of the UN Universal Declaration of Human Rights and the Conventions of the International Labor Organization in regards to prohibition and elimination of child labor and forced labor, freedom of association and collective bargaining, promotion of equal opportunity and fair treatment in employment and occupation, safe and healthy working conditions, payment of living wages and regular employment entitlements and non-excessive working hours." Polycoat's current Supplier Code of Conduct reserves the right of Polycoat to conduct its own verifications of Suppliers' certifications and self-assessments.

Audits: Polycoat's Supplier Code of Conduct currently reserves the right of Polycoat to conduct onsite audits of its prospective and existing Suppliers through its own personnel on an announced basis to evaluate the Supplier's compliance with its certifications pursuant to Polycoat's Supplier Code of Conduct and accuracy of the Supplier's self-assessment. Polycoat reserves the right to conduct such audits through a third party independent auditor, on an announced or unannounced basis.

Materials: While Polycoat's current Supplier Code of Conduct requires our Suppliers to comply with all applicable laws, Polycoat does not currently request but is in the process of considering enhancement to require that Suppliers also expressly certify that materials incorporated into Polycoat's products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Accountability Standards: Polycoat currently has a written Code of Conduct policy applicable to all Polycoat employees that addresses compliance with all applicable laws. Polycoat's Code of Conduct expressly addresses how Polycoat employees are to deal with our Business Partners which include our suppliers, service providers, agents and distributors: Polycoat expects our business partners to share the same ethical values as Polycoat, including those reflected in Polycoat's Code of Conduct and the UN Global Compact. Polycoat also has internal accountability standards and procedures, including disciplinary action for its employees who fail to meet Polycoat's Code of Conduct standards. Polycoat employees are encouraged to report violations of the Code of Conduct under the Polycoat Code of Conduct.

Training: Polycoat is in the process of confirming that each employee having direct responsibility for supply chain management receives training with respect to mitigation risks of human trafficking and slavery within the supply chain, and managers are required to confirm compliance with the Polycoat Code of Conduct annually.

As we expand our business activities and work with Suppliers domestically and globally to meet customers' needs, it is important to preserve our collective commitment to human rights and safety in our supply chain.