California Transparency Act

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

The California Transparency in Supply Chains Act of 2010, California Civil Code § 1714.43 (the “Act”), requires retail and manufacturing companies to disclose what efforts they have taken to ensure their supply chains are free from slavery and human trafficking. Clougherty Packing, LLC d/b/a Farmer John makes the following disclosures in accordance with the Act:

Verification of Product Supply Chains: Clougherty Packing, LLC is committed to providing high-quality, safe products through responsible business practices. To that end, Clougherty Packing, LLC has developed Supplier Responsibility Principles http://2010csr.hormelfoods.com/wp-content/uploads/2011/08/Supplier-Responsibility-Principles.FINAL_.08.30.2011.pdf to outline its expectations for suppliers, a copy of which is provided to key suppliers. As part of Clougherty Packing, LLC’s Supplier Responsibility Principles, suppliers must be in compliance with all applicable laws and regulations relating to working conditions. Clougherty Packing, LLC does not tolerate child labor nor forced or involuntary labor, including bonded, indentured and involuntary prison labor, and will not work with suppliers that do not adhere to these policies. Verification of suppliers is not conducted by a third party.

Auditing of Suppliers: Clougherty Packing, LLC does review its supply chain partners to assess compliance with both applicable laws and Clougherty Packing, LLC Supplier Responsibility Principles. We do not use third parties to conduct such reviews. Clougherty Packing, LLC does not routinely conduct independent, unannounced audits of suppliers but may do so if we have cause to believe they are not in compliance.

Certification By Suppliers: As noted above, Clougherty Packing, LLC expects all of its suppliers to adhere to Clougherty Packing, LLC Supplier Responsibility Principles. Clougherty Packing, LLC’s Purchase Order Terms and conditions further require all suppliers to comply with all applicable laws, including those relating to slavery and human trafficking.

Accountability Standards and Procedures: If we determine that a supplier is not in compliance with our standards or any applicable laws, including those relating to slavery and human trafficking, we will provide such supplier with the opportunity to remedy any potential non-compliance through the implementation of corrective action. Should the supplier continue to fail to meet our standards, we will initiate our supplier discontinuation process.

Training: Clougherty Packing, LLC Supplier Responsibility Principles are incorporated into all training of employees and managers who have responsibility for supply chain management and procurement.