CHAADS is opposed to human trafficking and forced labor at any level. The following constitutes our disclosure under the California Transparency in Supply Chains Act:

Verification

In order to do business with CHAADS, we require our suppliers and manufacturers to represent and warrant that they are in compliance with all laws, rules and regulations, which includes laws related to slavery, human trafficking, and the fair treatment of workers. On occasion, CHAADS may require that a social compliance audit be conducted before a purchase order is issued. CHAADS is committed to complying with all laws, rules, and regulations applicable to its operations and imposes that same commitment upon its manufacturers, suppliers and partners via contractual obligations.

Audits

While CHAADS does not, at this time, conduct audits of its suppliers with respect to slavery and human trafficking, we will continue to evaluate our options in this area.

Certification

As previously mentioned, CHAADS requires its suppliers and manufacturers to represent and warrant that they are in compliance with all laws, rules and regulations. We do not require any official certifications aside from these representations and warranties in our contracts with our suppliers and manufacturers.

Internal Accountability

CHAADS’s Code of Ethics requires every employee to be “in strict compliance with the letter and spirit of the law and to adhere to the highest principles of business ethics.” We interpret these requirements to include a prohibition against human trafficking, coerced labor and slavery, and treat them in this manner. An employee’s violation of the Code of Ethics may result in disciplinary action, up to and including termination.

Training

CHAADS expects its employees who have responsibility in supply chain management to be familiar with and adhere to CHAADS’s policy of opposing human trafficking and forced labor at any level. We are continuing to evaluate our procedures, including adding specific training for the individuals on our operations team who work directly with our suppliers and manufacturers.