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California Transparency in Supply Chains Act of 2010

RJAPA, Inc. ("Nada Sawaya") is committed to conducting business in a legal, ethical and responsible manner. We expect our suppliers to respect and adhere to the same business philosophy in the operation of their businesses.

The California Transparency in Supply Chains Act of 2010 (SB-657) requires retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their direct supply chain. To address the requirements of this Act, Nada Sawaya discloses the following:

Nada Sawaya shares with, and expects its direct product suppliers to adhere to and to implement, Nada Sawaya’s Supplier’s Code of Conduct. Nada Sawaya’s Supplier’s Code of Conduct addresses working conditions for suppliers and specifically prohibits the use of involuntary or forced labor, human trafficking, child labor, and harassment and abuse.

Nada Sawaya has communicated and will continue to communicate the requirements of our Supplier’s Code of Conduct to our direct suppliers to ensure that materials incorporated into our products comply with all applicable laws regarding slavery and human trafficking.

We do not currently engage in audits of our suppliers. However, we will consider measures such as auditing or third party verification for any suppliers we determine to be in significant risk of violating our Supplier’s Code of Conduct. If we suspect a supplier is involved in these activities, we will conduct an inquiry. In the event that a potential violation of human rights is identified, Nada Sawaya will promptly address the issue with the supplier and set expectations for how the situation is to be addressed. If a non-compliance issue is not resolved in a timely manner, then Nada Sawaya will re-evaluate its business relationship with the supplier, up to and including termination of the business relationship.

Nada Sawaya maintains internal accountability standards and procedures for employees and contractors who fail to meet our standards, including but not limited to prohibitions against slavery and trafficking.

Nada Sawaya provides training to ensure that its employees with direct responsibility for product supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including mitigating the risk of human trafficking and slavery.