California Transparency in Supply Chains Act

The purpose of the California Transparency in Supply Chains Act of 2010 is to address the global issue of human trafficking and slavery. Fres-co System USA, Inc. (“Fres-co”) is opposed to human trafficking and slave labor wherever it may exist, and is taking the following steps to ensure that these conditions are not present in Fres-co’s supply chain:

Supplier Assessments and Verification

Fres-co sourcing managers regularly interview suppliers about legal and other contractual compliance matters. Fres-co will make periodic visits to key suppliers’ facilities to make on-site, first-hand inspections.

Supplier Audits

Fres-co reserves the right to audit its direct suppliers. These audits will be conducted by Fres-co’s internal audit and/or supply chain teams, which are trained in assessing risks in Fres-co’s supply chain.

Supplier Certifications

Fres-co’s Code of Ethics and Business Conduct prohibits the use of slave labor and human trafficking, directly or indirectly, in Fres-co’s supply chain. Fres-co’s standard Purchase Order Terms and Conditions will include a representation and warranty that the supplier has procedures in place to assure Fres-co that the supplier has taken appropriate action to prevent slave labor and human trafficking in the manufacture and supply of goods or services to Fres-co. Any supplier that fails to certify its compliance with these principles may suffer a loss of business with Fres-co or may have existing agreements with Fres-co terminated.

Accountability

Fres-co’s Code of Ethics and Business Conduct includes, among other things, certification that Fres-co’s employees will comply with all applicable laws and regulations. Supporting human trafficking and slavery would constitute a violation of Fres-co’s Code of Ethics and Business Conduct, and such a violation could result in disciplinary action.

Training

Fres-co is committed to training employees and management who have direct responsibility for supply chain management and procurement. The goal of such training is to assure that Fres-co suppliers comply with all applicable laws and regulations and adhere to Fres-co’s policy of opposing human trafficking and slavery throughout the company’s supply chain.