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Corporate Disclosure in Compliance with SB657 California Transparency in Supply Chains Act

At Pharmavite, we are firmly committed to human rights and ethical standards of conduct in our business practices, and we seek strong partnerships with suppliers who share these same values. It is with these principles in mind that we will be requiring our suppliers to comply with our Supplier Code of Conduct which sets forth specific guidelines regarding labor, human rights (including a prohibition on slavery and human trafficking), health and safety and the environment.

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will go into effect, requiring retailers and manufacturers above a certain size doing business in California to disclose what efforts, if any, they have taken to eliminate slavery and human trafficking from their direct supply chains for goods offered for sale. The disclosure is aimed at providing information to consumers, allowing them to make better, more informed choices about the products they buy and the companies they support.

Verification: Pharmavite is actively engaging, through internal processes, in the verification of our product supply chain to evaluate and address risks of human trafficking and slavery. These internal processes include mapping our actual supply chain and examining not only the places we purchase from but also the types of products we are purchasing in order to determine the risks of human trafficking and slavery associated with the sourcing location and the product sourced. Pharmavite has engaged a qualified third party to assist it in assessing these risks. In compliance with US federal and state laws, Pharmavite itself uses only voluntary labor and does not engage in forced or involuntary labor of any kind or in human trafficking. In addition, Pharmavite’s Supplier Code of Conduct requires suppliers to only use voluntary labor and to refrain from using forced or involuntary labor (including slave labor, indentured labor, prison labor, bonded labor and other forms of labor provided or obtained by force, fraud, coercion or threats) or participating in human trafficking.

Auditing: Pharmavite requires suppliers to disclose all facilities producing products for Pharmavite. These facilities will be required to adhere to Pharmavite’s Supplier Code of Conduct. Based on the risk assessment conducted as part of Pharmavite’s verification of its product supply chain, certain suppliers will be subject to periodic audits, either unannounced or pre-arranged, by a qualified third party expert and/or by Pharmavite’s in-house auditors. Such audits will include on-site factory inspection and confidential interviews with employees and, where applicable, on-site contract workers.

Upon completion of all audits, the identified issues and recommendations to rectify violations observed will be discussed and documented with the audited facility. Factory management will be expected to address all identified issues as noted.

Certification: We also will be requiring our suppliers to certify their compliance with our Supplier Code of Conduct, including that the materials incorporated into the products sold to Pharmavite were produced in compliance with the laws regarding slavery and human trafficking in the country or countries in which they are doing business.

Accountability: Pharmavite maintains internal accountability standards for its own compliance with US federal and state laws including those relating to lawful labor practices. Pharmavite intends to hold suppliers accountable for their non-compliance with Pharmavite’s Supplier Code of Conduct. If Pharmavite discovers a violation of our Supplier Code of Conduct by a supplier, Pharmavite’s focus will be on working with the supplier to remedy the violation, upholding workers’ rights and improving the overall workplace environment. If a supplier does not correct the violation, we are prepared to end the relationship with that supplier.

Pharmavite’s senior leadership will have direct involvement and accountability for monitoring and ensuring compliance with the Supplier Code of Conduct. Periodic reports regarding supplier compliance with the Supplier Code of Conduct will be provided to Pharmavite’s senior leadership.

Training: Pharmavite employees and management, who have direct responsibility for supply chain management, are being provided with training on human trafficking and slavery, particularly with respect to identifying and mitigating risks within the supply chain of products. This training is being provided by a respected third party.

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