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California Transparency Act

Blue is committed to promoting socially responsible conduct and ensuring that the manufacture of all of our products is performed in compliance with the highest legal and ethical standards.  These standards are reflected in our Code of Ethics and Business Conduct (the “Code”) which states:

We respect the human rights of all people throughout the world.  We do not condone or permit the use of child, forced, or involuntary labor in any of our operations. We expect our suppliers and other business partners to have a similar commitment to human rights and to provide their employees with proper pay and a clean, safe, and healthy workplace.

All Blue employees are expected to know and abide by this Code. Each employee must periodically acknowledge that they have read and agree to comply with the Code, and Blue is in the process of developing training modules on the content of the Code which will be mandatory for every employee.  It is Blue’s policy to investigate claims of violations of the Code and to ensure prompt and consistent action against violations of this Code, which may include reassignment, demotion, termination and, in the event of criminal conduct or other serious violations of the law, notification of appropriate governmental authorities. 

Prior to doing business with any supplier or co-manufacturer Blue conducts a comprehensive a stringent qualification process.  From time to time Blue does conduct regular audits of its suppliers and co-manufacturers.  Blue is currently evaluating what additional auditing it may do specifically targeting compliance with laws relating to ethical and responsible standards of behavior including those dealing with human rights (human trafficking and slavery and conflict mineral sourcing).

Blue’s standard contract templates have been updated to include new provisions to require suppliers and co-manufacturers and their respective subcontractors and suppliers to comply with all state, national and international laws relating to ethical and responsible standards of behavior including those dealing with human rights.  The new templates further require suppliers and co-manufacturers to represent that they have adopted appropriate and effective policies to ensure compliance with these laws including, training, auditing and certifications.  As existing contracts come up for renewal, Blue intends to add similar representations to the renewal contracts, and in the interim, Blue intends to obtain a certification letter from its existing suppliers and co-manufacturers with a similar representation.  As suppliers and co-manufacturers become more familiar with the social responsibility representations and certifications, Blue will evaluate whether to require periodic compliance certifications, self-assessments and/or compliance audits. No decisions have yet been made as to whether future assessments of compliance with laws relating to ethical and responsible standards of behavior will be verified, or supplier/co-manufacturer audits conducted by independent third parties.