CA Transparency Act

The California Transparency in Supply Chains Act requires companies doing business in California to disclose their efforts to prevent slavery and human trafficking from their direct supply chain and, if such practices are present, to disclose what they are doing to eradicate those practices from their supply chain. Nutrigain has no reason to believe that its supply chain is engaged in slavery or human trafficking and it is taking the following actions to prevent slavery and human trafficking from its direct supply chain for tangible goods offered for sale in compliance with the California Transparency in Supply Chains Act:

Verification: Nutrigain is committed to fair labor practices within our supply chain. To that end, all of our suppliers are required to agree and comply with Nutrigains Supplier Statement of Basic Standards as part of our contracting process. The Supplier Statement of Basic Standards includes prohibitions against child labor, forced or prison labor, and mandates that suppliers provide appropriate compensation and work environments for their workers. Our expectation is that suppliers will abide by our Statement of Basic Standards and that they will hold their suppliers to similar standards as well.

Furthermore, Nutrigain has implemented a multi-disciplinary, multi-tiered approach and assessment for detecting and taking corrective action against slavery and trafficking in its supply chain. Annual communication to all of our direct suppliers regarding their obligation to comply with worldwide slavery and human trafficking laws assists in this verification process.

Supplier Audits: Nutrigain routinely conducts pre-engagement audits and periodic on-site assessments of suppliers as part of its initial supplier screening and selection process. Supplier pre-engagement audits and subsequent on-site assessments provide the opportunity to: evaluate capability, capacity and quality controls; observe working conditions; and may include visits to living conditions and eating facilities. Nutrigains Supplier Statement of Basic Standards, which suppliers must agree to in order to do business with Nutrigain, also provides Nutrigain with the ability to access supplier facilities to ensure compliance with our labor and work environment standards.

These pre-engagement audits and on-site assessments vary in frequency based on a number of factors, including: the nature of the products involved, the relevant country risks for where the supplier is located, supplier past performance and other factors, such as Nutrigains relationship with a supplier, or whether JOI has any reason to suspect that the supplier is not living up to our expectations.

Supplier Certifications: Nutrigain requires direct suppliers to declare that the materials incorporated in the products they supply to Nutrigain comply with laws regarding slavery and human trafficking, general use of labor, and working conditions. This declaration is included in Nutrigains Statement of Basic Standards to which all suppliers are required to adhere.

This requirement applies to 100% of Nutrigains first tier active suppliers through the Statement of Basic Standards and the requirement to adhere to this standard is repeated annually to all Nutrigain suppliers. This standard is communicated annually to suppliers through Nutrigains pro-active supplier communication plan. This plan reiterates the need for suppliers to comply with Nutrigains Statement of Basic Standards, and includes an internal audit of the distribution of this information to evaluate and ensure supplier understanding, acknowledgment, and adherence to this policy. Additionally, this requirement is, or will be, applicable to all business groups as mandated per either the Purchase Order or Terms and Conditions of doing business with Nutrigain.

Additionally, Nutrigains Statement of Basic Standards includes specific certification from suppliers that any parts, materials, products or assemblies supplied to Nutrigain comply with applicable laws regarding slavery and human trafficking of the country or countries in which suppliers are doing business. This serves as verification that suppliers’ product supply chain standards include evaluation and address risks of human trafficking and slavery, and that they comply with national and international laws prohibiting slavery and human trafficking.

Internal Accountability: Nutrigain maintains internal accountability standards and procedures for employees failing to abide by the Supplier Statement of Basic Standards. Additionally, every Nutrigain employee is required to demonstrate that they received, read and understand Nutrigain Code of Conduct, which commits Nutrigain and its employees to following the law wherever Nutrigain conducts business, and to behave with the utmost integrity. All new hires must review and acknowledge receipt of the Code of Conduct and Nutrigain requires that the Code of Conduct be re-acknowledged every two to three years by all existing employees.

Lastly, Nutrigain has implemented a Slavery and Human Trafficking Grievance Mechanism, which allows Nutrigain to receive any additional relevant information from internal and external parties that may not have been uncovered through the due diligence process in supply chain transparency as it relates to slavery and human trafficking. This Grievance Mechanism is located in Nutrigains Corporate Governance section of our website.

Internal Training: Nutrigain has performed internal training with company employees and management who have direct responsibility for supply chain management on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. These internal groups include individuals from Management, Purchasing, and Engineering.

Nutrigain has created awareness and training for the relevant supply chain employees regarding human trafficking and slavery through specific and repetitive internal activities that include but are not limited to: initial and follow up training sessions; publication of training slides, reference guides, best practice guides, and FAQs on Nutrigain intranet for access to all relevant supply chain employees; and, implementation, management, and publication of a detailed project plan to continue Nutrigain efforts to prevent human trafficking and slavery from entering its supply chain.