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Fair Labor Practices

The California Transparency in Supply Chains Act of 2010 requires certain manufacturers to disclose to the public the extent of their efforts, if any, in the area of eradicating slavery and human trafficking in their supply chain.

North Technology Group Ethics Policy

North Technology Group, LLC (“NTG”), and its subsidiaries, are committed to complying with the applicable laws and expects its employees and suppliers to comply with all applicable laws and regulations, including those governing working conditions and fair business practices. NTG, and its subsidiaries, have had a Corporate Ethics Policy instituted for over a decade, and each NTG employee receives a copy of the Policy and is bound by the requirements of said policy. The Corporate Ethics Policy delineates specific protocol for reporting any breach or ethics violations within the organization. NTG, and its subsidiaries, take pride in ensuring excellent working conditions and fair wage and benefits packages for all employees in its worldwide manufacturing operations.

NTG complies with the Supply Chains Act disclosure requirements as follows:

Supply Chain Verification: NTG, and its subsidiaries, do not formally verify its supply chain to address the risks of slavery and human trafficking. Notwithstanding the forgoing, management and personnel at NTG’s subsidiaries, regularly make site visits to most suppliers which provide the organization with some understanding of supplier conformance with the applicable laws. Moreover, NTG’s largest subsidiary, North Sails Group, LLC, is primarily vertically integrated in its’ supply chain, thereby providing the organization with confidence that all applicable laws are adhered, and its workers are enjoying favorable working conditions. Site visits are conducted internally- not by third parties.

Audits: NTG, and its subsidiaries, do not conduct a formal audit of its suppliers’ compliance with NTG standards for slavery and human trafficking. As set forth above, management and personnel at NTG’s subsidiaries, regularly make site visits to most suppliers which provides the organization with some understanding of supplier conformance with the applicable laws. These visits are conducted internally, and site visits are generally announced in advance.

Certification: NTG, and its subsidiaries, do not currently require its suppliers to certify that materials incorporated into its’ products comply with laws regarding slavery and human trafficking in the country or countries where its suppliers do business. However, while the organization’s supply chain is linked globally, a vast majority of its suppliers are located in North America and other developed countries or are vertically integrated within the organization. As a result, there appears to be a de minimis risk that such suppliers are taking advantage of slavery and human trafficking.

Internal Accountability Procedures: NTG, and its subsidiaries, maintain internal accountability standards and procedures for all employees and stakeholders who fail to comply with the applicable legal requirements or the organization’s Corporate Ethics Policy. The Ethics Policy provides contact information for reporting suspected violations.

Training: NTG, and its subsidiaries, do not provide formalized training to its employees and management who have direct responsibility with the supply chains; however, employees and management are expected report any suspected violations by suppliers of any applicable law or violation of the organization’s Corporate Ethics Policy. Such a report would prompt an investigation by the organization.

NTG, and its subsidiaries, recognize the importance of making efforts to ensure that the organization’s supply chain is free of any products that utilized forced labor, child labor, human trafficking and slavery. Accordingly, the organization is in the process of studying its supply chain operations and continuing to develop policies, to the extent practicable, that further the objective of eliminating products derived from forced labor, child labor, human trafficking and slavery.