CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

Ventura Foods is dedicated to conducting business in a lawful and ethical manner. Doing so sustainably requires that we balance the social, environmental and economic benefits and risks of our products. Suppliers play a key role in our efforts to ensure that we manage our global supply chain in a sustainable way. Our policy is to only work with suppliers who share our commitment to socially responsible and ethical business practices. Ventura Foods expects its suppliers to obey all laws, regulations and other governmental authorities of any country in which they do business, and to conduct themselves in a professional and ethical manner.

Ventura Foods’ commitment to ensuring that its supply chain is maintained in a socially responsible way includes, among other things, an expectation that suppliers not use forced labor of any kind, including human trafficking and slavery, to produce the products they provide to Ventura Foods. To monitor compliance with its expectations, Ventura Foods encourages suppliers to sign a written certification that it complies with all laws and regulations, including those relating to slavery and human trafficking.

Further, Ventura Foods audits potential new and current suppliers from time to time to determine if they are meeting the requirements of Ventura Foods. On an annual basis, suppliers are selected for audit using a risk-based approach. Supplier participation in the audit process is mandatory and failure to meet the requirements of Ventura Foods may result in discontinuation of the supplier relationship.

Suppliers are also encouraged to enter into written agreements with Ventura Foods. Ventura Foods’ purchasing agreements require suppliers to comply with applicable laws within the country of business, including those laws regarding human trafficking and slavery, and specify the requirements by which our suppliers must abide.

We have not been made aware of any instances where forced labor or child labor was used by Ventura Foods or in our supply chains during the reporting period. Should such instances come to light, the following remediation plan will be enacted by Ventura Foods immediately:

Investigation: We will conduct a thorough investigation, likely involving an independent third party (potentially an accredited SMETA auditor), to confirm the non-compliance.
Corrective Action Plan (CAP): We will work to develop and implement a corrective action plan to promptly address and correct the non-compliance.
Support and Engagement: We will monitor the activity, finding ways to engage and support within our capabilities, including access to expert networks to ensure elimination of all violations of workers’ rights and safety.
Termination Clause: In the event of serious or persistent non-compliance or failure to implement the CAP, we reserve the right to terminate any and all business relationships.
Loss of Income: In the unfortunate circumstance that we find a confirmed instance of forced or child labor, our remediation plan would include prioritizing the child’s safety, education and long-term well-being and measures to remediate the loss of income to the most vulnerable affected workers and their families. This would be done in consultation with local nonprofit organizations or expert third-party organizations to ensure appropriate compensation and a proper grievance mechanism is established for aggrieved workers.

Ventura Foods encourages its employees who are responsible for supply chain management to obtain training on how to mitigate risks within the supply chain. Such training may include internal presentations, seminars or webinars.

Ventura Foods recognizes the importance of fair labor practices and is committed to doing its part to eradicating slavery and human trafficking. Ventura Foods maintains internal accountability procedures for its employees and contractors. Ventura Foods also provides ethical and compliance training on the company standards and code of conduct for its employees and management.