CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

            EFCO Corporation supports the California Transparency in Supply Chains Act of 2010. EFCO Corporation expects its suppliers to have commitment to social responsibility. This would include sustainable environmental programs to benefit their community and the society at large, adherence to internationally recognized child labor laws, and practicing diversity and respect within the workplace. These values and expectations are specifically stated in EFCO’s Supply Management Policies. EFCO Corporation’s Purchase Order Terms and Conditions require that all suppliers adhere to applicable laws, including those relating to human trafficking in any form.

            EFCO Corporation regularly reviews its supply chain to consider risks and compliance with both applicable laws and EFCO Corporation’s policies and standards. We do not use third parties to conduct such review. EFCO Corporation’s Purchase Order Terms and Conditions give us the right to audit our suppliers. We do not routinely conduct independent, unannounced audits of our suppliers but may do so if we have cause to believe they are not in compliance. EFCO Corporation requires its suppliers to warrant that materials comply with the laws regarding slavery and human trafficking. Our stated policies together with the Purchase Order Terms and Conditions clearly communicate to suppliers that EFCO will not do business with them if they fail to adhere to such laws. EFCO Corporation’s standards and values are incorporated into all training of employees and managers who have responsibility for supply chain management.

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