CA Supply Chains ACT and CSR

Oilseeds adheres to the supply chain transparency principles set forth under the California Transparency in Supply Chains Act of 2010 (SB 657), as follows:

• Employees of Oilseeds and/or its ultimate parent, Fuji Oil Holdings Inc., visit its direct suppliers to assess, among other things, the risks of slavery and human trafficking in the product supply chain.
• Oilseeds’ supplier verification process is reviewed by management on a periodic basis. This process includes supplier visits, obtaining written certifications, and includes contractual representations to verify compliance with Oilseeds’ standards and guidelines.
• Oilseeds requires its direct suppliers to provide written certification, or to agree by contract with Oilseeds, that the materials incorporated into the products supplied comply with (a) the laws prohibiting slavery and human trafficking of the countries in which they do business, and (b) Oilseeds’ CSR Action Guidelines as set forth in Section I of this Statement.
• Compliance programs of Fuji Oil group companies, including Oilseeds, maintain internal accountability standards and procedures for employees and contractors failing to meet Oilseeds’ standards regarding slavery and human trafficking. If employee or contractor compliance deficiencies are identified, Oilseeds provides the supplier with a written notice and a specified period of time to take corrective action. If the supplier fails to satisfactorily remediate the identified deficiencies within the specified cure period, Oilseeds reserves the right to escalate the matter, including by suspending or terminating the supplier relationship.
• Oilseeds has mandatory annual training for all employees and contractors with direct responsibility for supply chain management with respect to avoidance of human trafficking and slavery within its supply chain.
• Oilseeds has a mandatory reporting requirement for all of the above, and a hotline procedure is in place to facilitate such reporting. Oilseeds maintains a strict non-retaliation policy to protect any employee, contractor, or third party who reports a suspected violation in good faith. All reports are treated confidentially to the extent permitted by law.

Oilseeds International, LLC (“Oilseeds”), a member company of the Fuji Oil Group, adheres to the CSRAction Guidelines established for Fuji Oil Group suppliers as set forth below. These guidelines are incorporated by reference into Oilseeds’ supplier agreements and form part of the contractual obligations of each supplier engaged by Oilseeds. Failure to comply with these guidelines may result in corrective action, up to and including termination of the supplier relationship.

• Suppliers shall respect the human rights of their employees and shall not treat employees in an inhumane manner including verbal abuse and physical punishment.
• Suppliers shall not engage in forced labor, child labor, slavery, or human trafficking.
• Suppliers shall not practice discrimination or in hiring and employment.
• Suppliers shall comply with all applicable minimum wage laws and shall ensure fair compensation practices, including the payment of wages sufficient to meet applicable legal standards and the avoidance of exploitative wage arrangements.
• Suppliers shall respect the rights of employees to organize and bargain collectively to promote constructive negotiation between labor and management.
• Suppliers shall ensure that employees’ working hours, holidays, and use of leave of absence are properly managed so as to comply with applicable statutory standards.
• Suppliers shall strive to provide employees with a safe and healthy work environment.
• In the course of their business activities, suppliers shall comply with all applicable environmental laws and regulations, and shall take affirmative steps to conserve ecosystems and protect local and global environments, including by implementing measures to prevent environmental pollution and support deforestation-free sourcing practices. Suppliers are encouraged to align their environmental practices with the sustainability frameworks and environmental policies of the Fuji Oil Group.
• Suppliers shall observe all related laws and international rules, and ensure fair transactions and prevent corruption. This includes compliance with Anti-Bribery and Corruption and Anti-Money Laundering provisions under applicable federal law (including the Foreign Corrupt Practices Act), the laws of the State of California where applicable, and any other applicable international anti-corruption and anti-bribery regimes to the extent applicable to the supplier’s operations.
• Suppliers shall disclose information regarding the above items in a timely and appropriate manner.

Oilseeds employees receive training with respect to Anti-Bribery and Corruption, and Anti-Money Laundering compliance and are expected to adhere to best practices and remain vigilant in interactions with our business partners.