POLICIES

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS DISCLOSURE STATEMENT

Efforts to Eradicate Human Trafficking and Slavery within the Supply Chain

California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts to eradicate slavery and human trafficking from its direct supply chain.  Clover Technologies Group (“Clover”) is committed to ensuring that its employees and suppliers take appropriate steps to mitigate the risk of human trafficking and slavery from occurring in any aspects of its supply chain. In accordance with the Act, Clover makes the following disclosures:

Verification of Supply Chain

Clover verifies product supply chains through several methods, including requiring suppliers to complete a Social Accountability Form and audits for larger suppliers. Third parties are not utilized for verification.

Evaluation of Supplier Compliance

Clover conducts audits of larger suppliers to ascertain that they are in compliance with our Social Accountability statement. Included on this form are disclosure requirements regarding human rights laws, the requirement that an I-9 be on file for every employee, and prohibitions against forced or compulsory labor. Clover does not conduct audits of suppliers expressly to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.

Supplier Certification

Clover requires all suppliers to comply with applicable laws and regulations.

Internal Accountability Standards

Clover maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. In furtherance of the foregoing the policy identifies specific principles, including:

  • promoting fair employment practices,
  • providing fair and competitive wages,
  • prohibiting harassment, retaliation and discrimination,

Management Training

Clover intends to provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. That training has not yet been completed for all employees and managers but will be completed in 2016.

Policy Statement on Conflict Minerals

Clover Technologies Group (“Clover”) supports the humanitarian goal of ending violent conflict in Central Africa (the Democratic Republic of Congo (DRC) and surrounding countries of Republic of Congo, Central Africa Republic, South Sudan, Zambia, Angola, Tanzania, Burundi, Rwanda and Uganda) by adopting a policy on Conflict Minerals.

In response to the conflict, the Securities and Exchange Commission (SEC) promulgated the Conflicts Minerals rule to help end violence and human rights abuses by armed militant groups in the DRC Region by denying revenue to those groups that derive their funding from the control of mines in the region that product Conflict Minerals. In August of 2012 the SEC approved the final rule regarding the sourcing of Conflict Minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. Under this rule, publicly traded companies must report annually to the SEC the presence of Conflict Minerals originating from the DRC in either the products they manufacture or contract to manufacture, or use in the production process. Conflict minerals are defined as the minerals tin, tungsten, tantalum and gold.

Clover is not a publicly traded company nor do we directly purchase raw minerals that may be used in the manufacture of our products from smelters or mines. We do, however, use suppliers whose products may contain these minerals. In order to commit to responsible sourcing of Conflict Minerals throughout our supply chain we require our suppliers to submit certain information about any Conflict Minerals in the products or components they supply to Clover including, if known, the country of origin and the smelter(s) or refiner(s) used to process the Conflict Minerals.

Clover establishes compliance requirements for our direct suppliers regarding Conflict Minerals and provides them with the tools to facilitate reporting to the SEC. We will continue to evaluate our policies to ensure compliance and make adjustments where necessary.

Commitment to Excellence

At Clover, we strive to achieve the highest levels of customer satisfaction in every area of our business and integrate Quality, Environmental Sustainability and Health & Safety into our products, and the services we provide for our associates and customers. We are committed to the continuous review and improvement of the effectiveness of our management systems. Our commitment is based on the following key principles:

Quality

  • Rigorous process management
  • Associate empowerment and accountability
  • Compliance with all quality management standards and requirements
  • Continuous evaluation and measurement of quality objectives and targets

Environmental Sustainability

  • Prioritization of reuse whenever possible
  • Environmentally superior recycling methods
  • Consistent focus on minimizing waste and prevention of pollution
  • Compliance with all environmental laws and regulations
  • Continuous evaluation and measurement of environmental objectives and targets

Health & Safety

  • Provide a safe and healthy work environment
  • Continuous training to enable associates to work safely
  • Compliance with all governmental agencies, laws and regulations
  • Continuous evaluation and measurement of health and safety objectives and targets