CTL and its subsidiaries (collectively, the “Company”) make the following disclosures pursuant to the California Transparency in Supply Chains Act. The Company is strongly committed to maintaining high standards in supply chain management. We are pleased to provide the following summary description of our efforts to responsibly manage our supply chains.

1. The Company works directly or with partner companies such as  (QIMA) to help ensure the safety, quality, and socially responsible manufacture of the Company’s direct sourced products at factories that manufacture the final direct sourced products for CTL.  Moreover, senior members of the Company meet periodically to verify and evaluate the Company’s product supply chain and address the risks of human trafficking and slavery. 
2. The Company periodically arranges for audits of its Direct Suppliers for, among other things, the purpose of evaluating the Direct Suppliers’ compliance with the Company’s standards and business practices guidelines as well as applicable laws related to human trafficking and slavery, as defined by the laws in the country in which the Direct Supplier is located. The periodic audits are independent and both announced and unannounced by QIMA.
3. The Company requires each direct supplier to certify that materials incorporated into the product which it supplies to the Company comply with the laws regarding slavery and human trafficking of the country or countries in which the supplier is doing business in accordance with CTL’s Code of Conduct. 
4. The Company maintains internal accountability standards and procedures for employees’ or contractors’ compliance with the Company’s Code of Ethics & Business Conduct, including preventative, and corrective actions for workers failing to meet Company standards and protections for those who face potential failures.
5. The Company provides Company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Additionally, these employees and managers attend regular calls with professionals and industry associations to help ensure the safety, quality, and socially responsible manufacture of the Company’s direct sources products.
6. CTL is a member of the Responsible Labor Alliance.  The RLI is a multi-industry, multi-stakeholder initiative focused on ensuring that the rights of workers vulnerable to forced labor in global supply chains are consistently respected and promoted.