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California Supply Chain Transparency Act
California Supply Chain Transparency Act

Disclosed under the California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act required retailers and manufacturers with operations in California to disclose specific efforts to eliminate slavery and human trafficking in their direct supply chains. A-Premium has a long history of protecting and promoting human rights and conducting business in an ethical manner. Our long history of promoting ethical business practices is reflected in our Business Conduct Policy, which all A-Premium employees are required to acknowledge and abide by, and we regularly provide all employees with training on these policies.

To help fulfill our commitment to human rights and ethical business practices in the supply chain, A-Premium provides its business conduct policies to all our suppliers and requires all our suppliers to comply with these policies. Our standard supply contracts and the terms and conditions of doing business require all suppliers of A-Premium to fully comply with all applicable laws, including those relating to the prohibition of slavery and human trafficking. In addition, we require our suppliers to comply with the supplier standards published by A-Premium, which requires all suppliers to comply with relevant laws related to fair compensation, working hours, child and forced labor, as well as many other regulations designed to support human rights. A-Premium reserves the right to verify that its suppliers always comply with these terms and conditions, and has the right to terminate the relationship with any supplier who does not comply with these terms and conditions.

Verification: A-Premium currently does not verify suppliers in its supply chain to assess and address the risks of slavery and human trafficking. Although A-Premium does not conduct third-party verification of its suppliers' compliance with anti-slavery and anti-trafficking laws, A-Premium continuously uses its internal resources to regularly visit and inspect its suppliers' business premises to ensure compliance with anti-slavery and anti-human trafficking laws.

Audits: A-Premium currently does not conduct independent and unannounced formal audits of its suppliers to assess whether they comply with A-Premium's supply chain anti-slavery and anti-human trafficking standards. However, A-Premium uses its internal resources to regularly visit and inspect the business premises of its suppliers to ensure compliance with anti-slavery and anti-human trafficking laws.

Certification: A-Premium does not require all its suppliers to provide any certifications regarding compliance with the anti-slavery and anti-human trafficking laws of the countries in which it operates. However, A-Premium requires its suppliers not to support, promote or participate in slavery or human trafficking and requires suppliers to comply with the anti-slavery and anti-human trafficking laws of their country or region.

Accountability: A-Premium attaches great importance to slavery and human trafficking and will continue to make every effort to manage its supply chain responsibly and strive to eliminate human trafficking and slavery. A-Premium expects employees in the supply chain to comply with all applicable laws and regulations related to anti-human trafficking and anti-slavery. A-Premium will investigate all reports of suspected violations. If the investigation results show that corrective measures need to be taken, a-Premium will take appropriate measures, including disciplinary action, dismissal and possible legal proceedings. Disregard or deliberate disregard of the law is intolerable and may lead to disciplinary action.

Training: A-Premium requires our employees to provide proof of their understanding and compliance with the Code every year. A-Premium is conducting awareness training on anti-slavery and anti-human trafficking for its employees and management directly responsible for supply chain management, especially for mitigating risks with its supply chain.

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