CA Transparency in Supply Chains 2010

Oberto Brands supports the goals of the California Transparency in Supply Chains Act of 2010. Oberto Brand’s efforts in this area include the following:

1. Product Supply Chains/Suppliers

At this time Oberto Brands does not have specific steps in place to verify its product supply chains to evaluate and address risks of human trafficking and forced labor. However, each of Oberto Brands’ suppliers is being asked to certify its compliance with all applicable laws. Oberto Brands is in the process of collecting additional certifications from each of its suppliers (an “Ethical Sourcing Certification Letter”) that they do not use any form of forced labor or permit human trafficking in their businesses or supply chains.

2. Supplier Audits

At this time Oberto Brands does not conduct audits of its suppliers. The Ethical Sourcing Certification Letter that Oberto Brands is in the process of collecting will give it the right to audit any of its supplier’s facilities in order to verify compliance with the Ethical Sourcing Certification Letter. In the event that Oberto Brands discovers any noncompliance, it shall have the right to demand corrective action or terminate the relationship.

3. Supplier Certification

Oberto Brands is in the process of requiring each of its suppliers to certify that materials incorporated into Oberto Brands’ product comply with all applicable laws. In addition, Oberto Brands is in the process of collecting an additional Ethical Sourcing Certification Letter that the suppliers do not use any form of forced labor or permit human trafficking in their businesses or supply chains.

4. Internal Accountability

Oberto Brands expects each of its employees and contractors to comply with all laws and to act with the utmost integrity in performing their job functions. Any employee or contractor who does not adhere to Oberto Brands standards and procedures regarding slavery and trafficking is at risk of being terminated. Oberto Brands is considering implementing a training program for certain of its employees around issues relating to ethical dealings with third parties including issues relating to forced labor and human trafficking.

5. Employee Training

While Oberto Brands does not currently train employees specifically on issues related to forced labor and human trafficking, it is looking into implementing such a training program, particularly with regard to mitigating risk, for certain of its employees who work in procurement and supply chain management.