California Transparency in Supply Chains Act

The Hartz Mountain Corporation California Transparency in Supply Chains Act Disclosure

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB657) (the “Act”) went into effect in the State of California. The purpose of the Act is to help further the elimination of slavery and human trafficking from the product supply chain for products being sold in within the State of California. The Act requires manufacturing companies such as The Hartz Mountain Corporation whose products are being sold within the State of California to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

Hartz strongly supports the goals of the Act and Hartz is committed to seeing every workplace around the world be free from slavery or forced labor, the trafficking in human beings and unlawful child labor. We respect and support international principles aimed at protecting and promoting human rights. To that end, Hartz has incorporated the principles of the ETI Base Code of the Ethical Trading Initiative (www.ethicaltrading.org) as part of Hartz’s Standards of Engagement for our supply chain partners. Our Standards of Engagement are designed to ensure that all suppliers operating within Hartz’s supply chain meet our standards for ethical conduct and compliance with law.

Hartz investigates, examines, evaluates, and addresses risks associated with, forced labor and human trafficking in our supply chain. Our Standards of Engagement include the following:

• Evaluating supply chain risks: Hartz conducts an extensive auditing process when a supplier seeks to become a supply chain partner with Hartz. The applicant must prepare and submit an extensive survey of its business operations, including its labor practices. Our Standards of Engagement specifically make clear that slavery or forced labor, and human trafficking, can have no place in any part of Hartz’s supply chain.
• Auditing suppliers: Hartz conducts audits of our supply chain suppliers, both when a supplier is first engaged and periodically thereafter, which audits can be unannounced.
  Supplier confirmation: Hartz requires its supply chain partners to confirm that products they supply to Hartz were produced in compliance with Hartz’s Standards of Engagement.
• Accountability: Hartz will take action against supply chain suppliers who fail to meet our Standards of Engagement, including without limitation termination of the business relationship.
• Training: Hartz management personnel and our supply chain employees are made aware of the unacceptability of slavery, forced labor and human trafficking in any part of the production of our products, and with the need to make every effort to mitigate the risks of these issues in our supply chain.