California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 became effective January 1, 2012 (the “Act”) and requires retailers and manufacturers doing business in California to disclose actions and efforts, if any, to eliminate slavery and human trafficking from their direct supply chains.

At Carton Packaging & Print, Inc. ("Carton"), we are committed to ethical business practices and social responsibility. We do not condone or knowingly support forced labor, and shall continue to make efforts to ensure this is reflected in our supply chain and in the partners with whom we engage.

To comply with requirements of the Act, we are disclosing the following information:

1. Risk Assessments

Carton performs assessments of suppliers on various risk factors, including suppliers’ labor practices and reputation. We attempt to visit many facilities in which products are made to ensure the suppliers’ quality and operational practices meet Carton standards and may during such process, assess certain labor conditions.

2. Auditing

We require manufactures comply with all applicable laws, which includes laws relating to labor, slavery and human trafficking. Generally, we require our manufacturers confirm that a third-party independent auditor has audited their manufacturing facilities to ensure they meet industry standards, including certain labor related practices, and make available to us any corresponding audit report for our review.

3. Certification Requirements

In addition to requiring manufactures to contractually represent that they comply with all applicable laws, Carton verifies third-party certifications, which may have requirements such as banning child and forced labor. Carton does not separately require manufacturers to provide any additional certification about human trafficking and forced labor.

4. Internal Accountability

Carton is committed to social responsibility and ethical conduct in the workplace. We consider our requirements that each employee comply with the law and conduct business in a fair and transparent manner as including a prohibition against human trafficking, coerced labor and slavery.

5. Training

Currently, we do not provide any specific training for Carton personnel responsible for supply chain management with respect to the Act, and the topics covered therein. However, we continually assess all of our policies and procedures, including training practices, and update such materials when opportunities may arise.