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Supply Chain Transparency Act 2010

At S. Martinelli & Company we are very concerned with the global scourge of human trafficking and slavery. We assert that our Company does not engage in such despicable practices, and we refuse to do business with companies that engage in or support the practice of human trafficking or slavery.

On January 1, 2012, the California Transparency in Supply Chains Act went into effect in the State of California. This law requires manufacturers and retailers to make certain disclosures regarding their efforts to address the issue of slavery and human trafficking in their supply chains.

In compliance with this Act, S. Martinelli & Co. discloses the following:

  1. We are currently engaging in verification of our product supply chain to evaluate and address the risks of human trafficking and slavery. This verification is not being done by a third party.
  2. We are planning on auditing our suppliers to evaluate their compliance with State and Company standards for eliminating trafficking and slavery in supply chains. We are in the process of determining whether these audits will be done by a third party, and whether they will be unannounced.
  3. We are in the process of requiring direct suppliers to certify that materials incorporated into the products they supply to us comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
  4. We are developing our internal accountability standards and procedures for employees or contractors failing to meet our standards regarding slavery or trafficking.
  5. We are planning to provide all Company employees and management with training on issues related to human trafficking and slavery and our policies related to the CTSCA.