California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act of 2010 is focused on eliminating slavery and human trafficking from global supply chains. This act requires companies that do business in California to disclose what efforts their organizations engage in to ensure their supply chain is free of human rights violations.

Novolex Corporation's Social Responsibility

Novolex Corporation is a holding company, many of whose subsidiaries do business in California. Our subsidiaries have implemented comprehensive corporate social responsibility programs to ensure that they operate within the highest standards of business ethics and in accordance with all applicable laws and regulations.

As good corporate stewards, our subsidiaries will not work with any suppliers that engage in human trafficking and/or slavery. As part of our comprehensive social responsibility program, our subsidiaries conduct audits which serve as a starting point to understand suppliers' compliance infrastructure. Issues such as human trafficking, slavery, forced/prison labor and child labor are zero tolerance violations and our subsidiaries will not conduct business with suppliers having such practices. The audits allow us to verify that all labor at the factories supplying our subsidiaries is voluntary.

Verification: Verification of social responsibility standards consists of:

• Both internal and external audits
• Random onsite visits at factories
• Worker Interviews

Certification: Certification of compliance is required:

• Key program documents such as our Code of Conduct and Supplier Handbook outline our strict social responsibility requirements
• All Suppliers that sign the Novolex Code of Conduct must adhere to our comprehensive social responsibility requirements and are to follow all law and regulations in the jurisdictions in which our products are manufactured

Training: To improve our supply chain our businesses work with our suppliers on an ongoing basis through:

• Supplier training/ development; capacity building; root cause analysis and onsite visits to ensure our suppliers are meeting long- term compliance objectives
• Various forms of training to include: in person; roundtables; webinars and e-learning

Remediation: Where necessary, remediation may include:

• Comprehensive corrective action plans developed with suppliers to create long-term sustainable improvements
• Root-cause analysis to drive issue resolution