CA SB 657 Disclosure

On September 30, 2010, California Governor Arnold Schwarzenegger signed The California Transparency in Supply Chain's Act of 2010 (the "Act"), California Civil Code Section 1714.43(a)(1) into law. The legislation requires companies to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking. Pelican Products is a retail seller/manufacturer as that term is defined in the Act. In compliance with the Act, the following represents our required disclosure statement:

• As a company philosophy, we oppose any and all illegal and unethical treatment of people, including any acts of slavery or human trafficking. We are in the process of creating a Supplier Code of Business Conduct that will include our expectations for our suppliers to prohibit forced labor, slavery, and human trafficking within their supply chains.
• We require direct suppliers to certify that all applicable local laws dealing with slavery and human trafficking are followed for products that are sold to Pelican Products.
• We are currently in the process of securing agreements from all suppliers to allow us reasonable access to applicable plants and records to confirm compliance as it relates to S.B. 657. Audits will be conducted by internal or third party resources.
• We will provide company employees and management, who have direct responsibility for supply chain management specific training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. We are in the process of developing accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.