SB657 COMPLIANCE

California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act of 2010 (SB 657), requires us to disclose our efforts to eradicate human trafficking and slavery from our direct supply chains. In support of this law, Igloo Product Corporation has provided the following required disclosures:

Verification
We verify that our supply chain is not tainted by slavery or human trafficking by directly approving the materials that are used by our suppliers. We work closely with our suppliers and lock-in their sources of supply. We assure these things ourselves and do not delegate this responsibility to a third party.

Auditing
All of our suppliers have passed a rigorous social compliance audit which ensures that all workers are paid a legal wage and that the facility is free from coerced labor. When an independent 3rd party audit is not available, we audit them ourselves. The audits are generally announced rather than unannounced, since they require significant supplier cooperation and involvement, but the audits always include random documentation checks designed to detect slavery and human trafficking.

Certification
We require that all our suppliers agree to our Code of Conduct. Our social compliance system relies more heavily on audits than certification since we assume that individuals who conduct human trafficking would have no hesitation to falsify a certificate.

Internal Accountability
All suppliers must agree to our Code of Conduct which establishes a no tolerance stance on slavery and human trafficking. To date, we have not discovered any problems in our supply chain, but we would have no hesitation in acting if we were to uncover a problem.

Training
All team members involved in our supply chain acknowledge that they have been adequately trained about slavery and human trafficking.