Disclosures

Helena Chemical Company's ("Helena's") Disclosure pursuant to the  California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act of 2010 ("Act") took effect on January 1, 2012, requiring manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Helena is a retail seller/manufacturer as the term is defined in section 1714.43(a)(1) of the Act.  Accordingly, Helena provides the following disclosure of the measures it takes to uphold the standards of conduct among its employees, business partners and suppliers.

Helena's efforts to eradicate slavery and human trafficking in its supply chain include the following:

Written Policies and Procedures

Helena maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain, including Helena's Ethical Sourcing Supplier Code of Conduct ("Code of Conduct").  Among other provisions, the Code of Conduct requires all Helena suppliers to comply with all applicable labor laws, rules, and regulations including but not limited to all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in section 1714.43 of the Act, and defined in California Penal Code section 236.1 et seq.

Supplier Certifications

Helena requires all major suppliers to certify their compliance with our Code of Conduct, including the provisions barring the use of slavery or human trafficking.  All suppliers are obligated to maintain necessary documentation to demonstrate compliance with Helena's Code of Conduct. Suppliers or employees found to be in violation of Helena's Code of Conduct will be dealt with pursuant to the Code of Conduct.

Supplier Compliance

Helena will engage its suppliers regarding compliance with Helena's Code of Conduct. Although Helena has not engaged a third party to conduct audits to verify compliance with Helena's Code of Conduct and to evaluate risks of slavery and human trafficking in its supply chain, Helena reserves the right to engage a third party to conduct announced audits.  Helena will visit suppliers to the extent that the need arises based on complaints, questions regarding compliance or information from reliable and applicable sources.

Accountability Standards

Helena will not tolerate violations of the Act and will endeavor to do business only with suppliers which are responsible and compliant regarding the goods sold to Helena.

Any supplier not able to certify its compliance will be required, as one condition to continuing its business relationship with Helena, to provide an action plan with the goal of achieving full compliance within a reasonable timeframe.

Employee Training

Beginning in 2012, Helena will provide training on slavery and human trafficking for all employees and management who have direct responsibility for supply chain management.  The training will be on an annual basis and focus on identifying and reporting slavery and human trafficking, as well as mitigating risks within the supply chain.  Helena will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in its direct supply chain.