California Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2010 (the "Act") requires certain companies manufacturing or selling products in the State of California to disclose their efforts (if any) to eradicate forced labor and human trafficking from their direct supply chains for goods they offer for sale.

Arcadia, Inc. and its subsidiary companies fully support the purpose and goals of the Act and oppose the use of slavery or human trafficking in the manufacture and distribution of our products. Although our policies are currently under development, we are continually exploring effective methods to ensure compliance with the Act and eliminate the presence of slavery or human trafficking in our supply chain. Arcadia is developing policies to require that its suppliers certify that materials shipped to Arcadia are free from any taint of slavery or human traffic. Arcadia is also developing internal accountability standards and procedures designed to ensure compliance, along with the appropriate training to mitigate risks within its supply chain.

Obeying all applicable laws, in letter and in spirit, is the foundation on which Arcadia's business ethics standards are built. Arcadia's Code of Business Conduct and Ethics requires all Arcadia employees to obey all local, regional and federal laws of the locations where Arcadia operates, including laws regarding slavery and human trafficking. Further, Arcadia takes seriously all potential legal or Code of Business Conduct and Ethics violations, and encourages all persons subject to its Code to preserve Arcadia's highest standards for business ethics and integrity by reporting suspected violations to their supervisors, human resources representatives, and others in the company with direct responsibility for the Code of Business Conduct and Ethics.