LEBON LIGHTING strives to maintain an ethical work environment that promotes dignity and respect, and is committed to positive labor and environmental practices in its own facilities and at the facilities of its suppliers. The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California, like LEBON LIGHTING, to disclose their efforts to eradicate slavery and human trafficking from their direct supply chain to tangible goods offered for sale. LEBON LIGHTING makes the following disclosures, as required by the Act and, with respect to its efforts to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale, and confirms that LEBON LIGHTING employs the following practices:

Verification

LEBON LIGHTING’s policies and standards dictate that its suppliers refrain from the direct or indirect use of forced labor and any form of human trafficking. Suppliers are required to certify that they comply with LEBON LIGHTING’s policies and standards.

Auditing

Suppliers are required to demonstrate adherence to LEBON LIGHTING’s policies and standards prohibiting the use of forced labor and human trafficking by permitting social and environmental audits. These audits are conducted by LEBON LIGHTING employees and independent third-party audit firms.

Certification

LEBON LIGHTING requires that its suppliers agree to a Vendor’s Agreement which, among other things, requires them to comply with all applicable laws and regulations, provide a safe and sanitary workplace free from harassment and discrimination, and certify that materials incorporated into the products they supply to LEBON LIGHTING do not come from, and that they do not and will not knowingly engage in, any forced labor, slavery or human trafficking. The Vendor’s Agreement is intended to make it clear that LEBON LIGHTING does not intend to do business with suppliers that are engaged in slavery and human trafficking.

Internal Accountability

LEBON LIGHTING requires its employees to represent it, and to act at all times, in an ethical manner. LEBON LIGHTING seeks to create and maintain internal accountability standards and procedures for employees and contractors regarding slavery and human trafficking and to make it clear that DWR does not engage in and does not intend to do business with suppliers that are engaged in slavery and human trafficking. As part of these standards and procedures, LEBON LIGHTING will advise its employees and contractors to bring any suspected supplier issues involving slavery and human trafficking to the attention of LEBON LIGHTING’s management. Possible violations of DWR’s policy against slavery and human trafficking will be investigated and appropriate action taken, including possible termination of a violator’s relationship with LEBON LIGHTING.

Training

LEBON LIGHTING will provide periodic training for its employees and officers who have responsibility for supply chain management. This training will provide information concerning human trafficking and slavery, familiarize them with identifying slavery and human trafficking issues and address mitigating the risk of such issues within its supply chain of products.