Human Trafficking and Slavery on the Supply Chain Solstice Marketing Concepts, LLC

Verification

Solstice's supply chain and legal executives meet on an annual basis, and informally as needed, to assess the risk of human trafficking and slavery in our supply chains and to assess whether our policies and procedures appropriately address those risks.

Audits

At Solstice, we contractually hold our suppliers to be in compliance with our Supplier Code of Conduct (the “Supplier Code”). We monitor our suppliers to identify possible areas of non-compliance with our Supplier Code. Solstice will not tolerate, and will investigate, any reports alleging human trafficking and slavery in the supply chain. Action is taken against any supplier for non-compliance, resulting in possible termination of the business relationship. Solstice does not conduct audits of suppliers that provide us with national brand products.

Certification

All suppliers of Solstice must adhere to our Supplier Code, which includes language strictly prohibiting human trafficking and slavery. The Supplier Code incorporates local laws and is based on international standards. The Supplier Code states that all suppliers must also comply with the country of manufacture's labor laws, whichever is stricter. Solstice also includes requirements of adherence to the Supplier Code in its Purchase Order Terms and Conditions, and we send periodic communications to suppliers making them aware of new laws or revisions to existing laws as appropriate. By accepting each and every purchase order, Solstice suppliers confirm their understanding and agreement to the standards set forth in the Vendor Code.

Internal Accountability

Solstice employees adhere to an employee Policy & Procedure Manual that informs them about the requirements of the Supplier Code of Conduct relating to human trafficking.

Training

The issue of human trafficking is addressed during annual meeting/training of employees. Employees responsible for supply chain-related decisions receive more detailed training on identifying and addressing human trafficking and slavery in our supply chain.