California Transparency In Supply Chains Act Disclosure Statement

California Transparency in Supply Chains Act of 2010

Parex USA, Inc ("Parex") is committed to responsible sourcing and specifically the eradication of human trafficking and slavery in our supply chain.  Parex follows the principles of the United Nations Global Compact, and in turn we expect our direct suppliers of Parex’s tangible goods for sale (“Supplier” or “Suppliers”) to adopt sound human rights practices, to treat workers fairly, with dignity and respect, and in all cases to eliminate human trafficking and slavery in their workplaces.

 Verification: Starting prior to 2018, Parex and its parent corporation introduced an employee Code of Conduct which specified that Parex is “particularly committed to the abolition of all forms of child or forced labor.”  Additionally, the Parex Supplier Code of Conduct requires Suppliers to certify that they "operate in full compliance with all laws, regulations and international standards," including but not limited to those relating to social and working conditions which require Suppliers to “respect the provisions of the UN Universal Declaration of Human Rights and the Conventions of the International Labor Organization in regards to prohibition and elimination of child labor and forced labor, freedom of association and collective bargaining, promotion of equal opportunity and fair treatment in employment and occupation, safe and healthy working conditions, payment of living wages and regular employment entitlements and non-excessive working hours.”

Parex’s current Supplier Code of Conduct reserves the right of Parex to conduct its own verifications of Suppliers’ certifications and self-assessments.

 Audits: Parex’s Supplier Code of Conduct currently reserves the right of Parex to conduct on-site audits of its prospective and existing Suppliers through its own personnel on an announced basis to evaluate the Supplier's compliance with its certifications pursuant to Parex’s Supplier Code of Conduct and accuracy of the Supplier's self-assessment. Parex is considering whether expressly to reserve the right to conduct such audits through a third party independent auditor, on an announced or unannounced basis.

 Materials: While Parex’s current Supplier Code of Conduct requires our Suppliers to comply with all applicable laws, Parex does not currently request but is in the process of considering enhancement to require that Suppliers also expressly certify that materials incorporated into Parex’s products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

 Accountability Standards: Parex currently has a written Code of Conduct policy applicable to all Parex employees that addresses compliance with all applicable laws.  Parex’s Code of Conduct expressly addresses how Parex employees are to deal with our Business Partners which include our suppliers, service providers, agents and distributors: Parex expects our business partners to share the same ethical values as Parex, including those reflected in Parex’s Code of Conduct and the UN Global Compact.  Parex also has internal accountability standards and procedures, including disciplinary action for its employees who fail to meet Parex’s Code of Conduct standards.  Parex employees are encouraged to report violations of the Code of Conduct and are reminded at least once a year about their obligations under the Parex Code of Conduct.

Training: Parex is in the process of confirming that each employee having direct responsibility for supply chain management receives training with respect to mitigation risks of human trafficking and slavery within the supply chain, and managers are required to confirm compliance with the Parex Code of Conduct annually.

 As we expand our business activities and work with Suppliers domestically and globally to meet customers' needs, it is important to preserve our collective commitment to human rights and safety in our supply chain.