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California Transparency in Supply Chains Act

American Licorice Company (ALC) is committed to operating its business in accordance with ethical and moral standards and complying with all applicable laws and regulations in all of our operations. On January 1, 2012, the California Transparency in Supply Chains Act of 2010 went into effect, requiring retailers and manufacturers above a certain size that are doing business in California to disclose their measures used to track possible slavery and human trafficking in their supply chains.

ALC supports the goals of the California Transparency in Supply Chains Act of 2010 (CTSCA). ALC expects its associates and suppliers to be in full compliance with all applicable laws and regulations in their country of operation and to conduct themselves ethically with regard to human rights and labor practices in all business transactions.

In 2011 we established the American Licorice Social Compliance Requirements that sets forth ALC’s standards and expectations for suppliers (and in turn their suppliers) with respect to corporate and social responsibility. We require our suppliers to acknowledge their understanding of and adhere to the American Licorice Social Compliance Requirements, by signing our compliance requirements or providing a company statement stating they will comply with all applicable laws and regulations and renounce and abstain from forced labor, human trafficking and slavery.

Verification

The American Licorice Social Compliance Requirements require suppliers to renounce and abstain from the use of forced labor, human trafficking or slavery, and to agree that their suppliers are held to the same requirements.

ALC conducts risk assessments and gathers documents annually about suppliers and potential suppliers to identify potential high risk suppliers.

Audit

We evaluate the risk of human trafficking and slavery in our supply chain, rather than using a third party to audit our suppliers. Should we deem one of our suppliers to be high risk we reserve the right to conduct an audit. We may conduct an audit, or we may obtain an independent audit. Certain audits may be unannounced. If our audit reveals concerns about the potential for forced labor, human trafficking or slavery practices, we require a remediation plan or may discontinue doing business with the identified supplier.

Certification

By signing the American Licorice Social Compliance Requirements, suppliers agree to certify that they are complying with laws regarding slavery and human trafficking in the country of source, for all materials incorporated into the product.

Internal Accountability

All ALC associates who deal directly with our suppliers, contractors and service providers are expected to act ethically and are required to exercise due diligence in selecting and retaining any third party (e.g., consultants, suppliers, contractors) who supply, represent or do work for ALC. Our supply chain evaluation includes the assessment of risks in regards to forced labor, human trafficking and slavery.

Associate Training

A copy of ALC’s associate handbook which includes our procurement policy has been distributed to all of our associates, each of whom signed acknowledging receipt. ALC provides training and discussion of the handbook when each employee is hired. Additionally all associates who deal directly with our suppliers, contractors and service providers have received training on slavery and human trafficking.

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