On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) (the “Act”) went into effect in the State of California. The Act seeks to increase the quantity of information made available by manufacturers and retailers regarding their efforts to address the issues of forced labor and human trafficking in their supply chains. This allows consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Otter Products supports California’s efforts to protect human rights and enforce ethical labor practices by adopting the Electronic Industry Citizenship Coalition (EICC) Code of Conduct (the “EICC Code of Conduct”). The EICC Code of Conduct requires, among other things, that its direct suppliers ensure they do not engage in or support forced labor or human trafficking. In addition, the EICC Code of Conduct requires suppliers to adopt and maintain terms of employment for their employees that comply with local law and requirements of decency.

Otter Products' efforts to evaluate suppliers’ conformity to company standards and the EICC Code of Conduct and to prevent risks of forced labor and human trafficking in the supply chain include:

1. Verification of Product Supply Chains. Otter Products strives to establish close relationships with its suppliers and requires that they comply with all aspects of the EICC Code of Conduct including those aspects that relate to forced labor and/or human trafficking. In addition to internal verification of supplier compliance with the EICC Code of Conduct, Otter Products utilizes an independent third party to verify supplier compliance.
2. Supplier Audits. Otter Products reserves the right to verify supplier compliance with company standards and the EICC Code of Conduct. Otter Products utilizes independent third party auditors to perform announced supplier audits and verify supplier compliance. If Otter Products becomes aware of any actions or conditions not in compliance with its company standards and/or the EICC Code of Conduct, Otter Products reserves the right to demand corrective measures which may include terminating the supplier’s contract.
3. Certification Requirements for Direct Suppliers. Otter Products requires its direct suppliers to certify that materials incorporated into the products comply with the laws regarding forced labor and human trafficking of the country or countries in which they are doing business. Otter Products presents the EICC Code of Conduct as a total supply chain initiative and requires suppliers to certify that they require their next tier suppliers to comply, including compliance with laws regarding forced labor and human trafficking. Otter Products also requires suppliers to monitor the performance of their next tier suppliers against the requirements of the EICC Supplier Code of Conduct.
   
   As part of the requirements of the EICC Code of Conduct and specialized labor standards, suppliers are required to develop appropriate management systems, which include policies, procedures and associated documentation, to adhere to the requirements and any applicable laws and regulations, including those prohibiting forced labor and human trafficking. We confirm the existence and maintenance of those management systems through our supplier audit program (see section 2 above).
4. Internal Accountability Standards and Procedures. Otter Products requires its employees to comply with company policies, including, but not limited to, policies prohibiting the use of forced labor and human trafficking in its operations. Otter Products provides channels to report concerns about any potential violation of law or company policy including those related to forced labor or human trafficking. Otter Products promptly investigates any such reports and takes all necessary corrective actions.
5. Training. Individuals who have direct responsibility for supply chain management receive training on forced labor and human trafficking. The training helps individuals to identify and respond to issues related to forced labor or human trafficking in the supply chain as well as to mitigate risks with the supply chains of products.