Disclosures: California Transparency Act

As one of the largest foodservice packaging companies in North America, D&W Fine Pack LLC (DWFP) has always been committed to responsibly developing innovative packaging and material solutions that reflect our corporate culture of honesty, integrity, sustainability, and ethical and lawful business practices.

DWFP thoroughly supports the efforts of The California Transparency in Supply Chains Act of 2010 (the “Act”) to eradicate the exploitive effects of human trafficking, slavery and forced labor within the global supply chain. To that end, we are continually focused on fully complying with all applicable employment and legal requirements, and work in cooperation with business partners who share our values and expectations in humanely treating all people at every level of our chain of operations with dignity and respect.

In accordance with the Act, as a retail seller and manufacturer doing business in California with over $100 million in worldwide gross receipts, DWFP hereby discloses, at a minimum, the following procedures designed to fulfill the objectives of this Act:

• Verification: The Company does not presently engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery. However, it is our intent to establish a policy and utilize a third party auditor to conduct such a verification of all major suppliers.
• Auditing: The Company does not currently conduct audits of suppliers to evaluate supplier compliance with company standards regarding human trafficking and slavery in its supply chain. However, it is our intent to establish a policy and utilize a third party auditor to conduct such a verification of all major suppliers for legal compliance as well as technical and financial auditing.
• Certification: The Company does not currently require its direct suppliers to certify that materials incorporated into its product comply with laws regarding slavery and human trafficking in the country or countries in which they are doing business. However, this requirement is being incorporated into our supplier agreements.
• Internal Accountability: The Company does not currently maintain internal accountability standards and procedures for employees or contractors who fail to meet company standards regarding slavery and trafficking. However, a specific policy of accountability will be implemented as the pieces of our policy are implemented.
• Training: The Company does not currently provide company employees training regarding human trafficking and slavery issues for those who have direct responsibility for supply chain management.  However, such training including specifics with respect to mitigating risks will be provided to all appropriate supply chain employees.