California Transparency in Supply Chains Act Disclosure

Sunshine Raisin Corporation dba National Raisin Company has taken seriously its obligation to provide a safe and healthy work place for its employees, and to comply with all labor and employment laws. Similarly, National Raisin Company actively seeks to do business only with the vendors or suppliers who are equally dedicated to maintaining safe work places and complying with all applicable laws.

Slavery and human trafficking, including forced and child labor, are issues of a worldwide concern. In that regard, California has enacted the California Transparency in Supply Chains Act of 2010 (SB657). SB657 is designed to provide consumers with knowledge about the policies adopted by and procedures engaged in by companies with respect to verifying that their supply chains do not include companies engaged in slavery and human trafficking. National Raisin Company has adopted and does follow a policy aimed at keeping its supply chain free from vendors or suppliers who engage in slavery or human trafficking.

The National Raisin Company program requires its suppliers and vendors to be subject to periodic audits to verify compliance with applicable law, as well as National Raisin Company’s own standards regarding slavery and human trafficking, including forced or child labor. National Raisin Company conducts audits of its suppliers and vendors through announced visits to food ingredient and primary packaging suppliers and vendors, and further reserves the right for unannounced audits with or without cause. During such visits, National Raisin Company food safety auditor or an assigned third party auditor performs the audit. During such facility tours, National Raisin Company auditors take notes of correctable issues.

Upon completion of the audit, National Raisin Company auditors work with suppliers and vendors to remedy issues identified during audits and make sure corrective actions are taken. Such suppliers and vendors must certify to National Raisin Company that all goods are made in compliance with all applicable U.S. laws, as well as the laws of the country in which the products are produced, including those of secondary suppliers. In addition to on site audits and certifications, National Raisin Company maintains internal accountability procedures for the purpose of ensuring employees, suppliers, vendors and contractors meet National Raisin Company’s standards regarding slavery and human trafficking. If and when deficiencies are identified, National Raisin Company will take appropriate remedial action, up to and including termination of non-compliant employees, suppliers, vendors and contractors. National Raisin Company’s key procurement employees and management personnel are provided training on risks of slavery and human trafficking in a supply chain. National Raisin Company is available to assist suppliers in providing safe and healthy work places, upon request.