California Transparency in Supply Chains Act

Phillips Industries, Inc., unreservedly supports international efforts to combat human trafficking, slavery and forced labor, including those represented by the California Transparency in Supply Chains Act, and has accordingly instituted the following policies:

Verification: At least once annually Phillips Industries’ purchasing personnel shall require each of its direct suppliers to represent and warrant in a writing certified by a responsible officer of such supplier that the supplier is generally knowledgeable as to the laws governing human trafficking, slavery and forced labor in the jurisdictions in which the supplier manufactures any products supplied to Phillips Industries, and that such supplier at all times has been and shall remain in full and complete compliance with all such laws.

Audit: Phillips Industries does not conduct audits of its suppliers in respect to the subject matter of the California Transparency in Supply Chains Act, either directly or through third parties.

Certifications: At least once annually Phillips Industries’ purchasing personnel shall require each of its direct suppliers to represent and warrant in a writing certified by a responsible officer of such supplier that to the best of such supplier’s knowledge after due inquiry all secondary suppliers of materials to such supplier (which materials the supplier has incorporated or shall incorporate into products ultimately sold to Phillips Industries) at all times has acted and shall act in full and complete compliance with all applicable laws governing human trafficking, slavery and forced labor.

Accountability: Phillips Industries, Inc. shall at all times fully and completely comply with all applicable laws and regulations governing human trafficking, slavery and forced labor. Any personnel of Phillips Industries, Inc., found to have breached the policies here stated shall be subject to disciplinary action, including, if warranted, discharge. Any outside contractor performing services for Phillips Industries, Inc. found to have breached the foregoing policy shall be subject to immediate termination.

Training: All present and future purchasing personnel of Phillips Industries, Inc., charged with implementing the policies here stated have been, or shall be, required to carefully review the California Transparency in Supply Chains Act, and the California Department of Justice’s publication known as The California Transparency in Supply Chains Act: A resource Guide, and as well The State of Human Trafficking in California 2012, found at http://oag.ca.gov/human-trafficking/2012 and Gangs Beyond Borders: California and the Fight Against Transnational Organized Crime, found at http://oag.ca.gov/tco, and further to monitor the foregoing sources for relevant news and updates.