COMPLIANCE POLICIES

The California Transparency in Supply Chains Act requires companies manufacturing products in California to disclose what efforts they make to address human trafficking and slavery.

Valent is committed to the highest possible standard of corporate integrity, and we hold our suppliers and employees to the same standards. It is our expectation that all suppliers provide high-quality raw materials that are produced within compliance of all applicable laws.

At this time Valent does not require that our suppliers certify compliance with laws relating to human trafficking and slavery. Valent requires that strategic suppliers sign standard terms and conditions which require compliance with all laws including those related to slavery or human trafficking.

At this time Valent does not conduct audits of its strategic suppliers to evaluate their compliance with human trafficking and slavery. If evidence of human trafficking or slavery was discovered during on-site visits, by Valent personnel, remedial action would be taken.

At this time Valent does not require that our suppliers certify materials provided comply with laws relating to human trafficking and slavery.

All Valent personnel must comply with all applicable laws in order to comply with our Corporate Code of Conduct. Noncompliance with our Code of Conduct can result in corrective action or termination of employment depending on the circumstances and severity. Valent requires that strategic contractors sign standard terms and conditions which require compliance with all laws including those related to slavery or human trafficking. Noncompliance with our standard terms and conditions can result in corrective action or termination of contracts depending on the circumstances and severity.

Valent requires employees and management who have direct responsibility for procurement or sourcing to complete an online training course on Human Trafficking.

While no formal processes are in place to address the steps outlined in the California Transparency in Supply Chains Act of 2010, we believe we have established relationships with the high integrity supply chain partners who are complying with all laws.