UA 85349857-3

California Supply Chains Act

True Fresh HPP, LLLP
Supply Chain Transparency Disclosure
California Transparency in Supply Chains Act of 2010

True Fresh HPP, LLLP’s mission is to improve the safety of the U.S. food supply and to reduce food waste. True Fresh HPP, LLLP purses these goals in concert with environmental, socially responsible and ethical business practices. In 2010, the California Transparency in Supply Chains Act (the “Act”) (also known as SB 657) was signed into law. Statutes enacted to implement the Act went into effect on January 1, 2012. The Act requires disclosure of specific efforts to eradicate slavery and human trafficking. True Fresh HPP, LLLP is committed to conducting business in a lawful and ethical manner and we expect our suppliers to conduct themselves in the same way. We have policies aimed at combating slavery and human trafficking in our supply chains. This disclosure describes those policies.

Our suppliers are companies that supply us with equipment and expertise enabling us to provide high pressure pasteurization services to our clients, thereby improving the safety of the U.S. food supply and reducing food waste.

Our Supply Chain Transparency compliance plan centers upon certification of compliance with applicable law by our suppliers. Compliance with applicable law, in our view, is the best means of addressing issues associated with prevention of slavery and human trafficking.

In compliance with California’s Transparency in Supply Chains Act of 2010, True Fresh HPP, LLLP makes the following disclosures.

VERIFICATION
True Fresh HPP, LLLP is committed to fair labor practices within our supply chain. We therefore engage in verification of our supply chains through the use of reputable suppliers who comply with the Act. In addition, True Fresh HPP, LLLP requires certification of compliance, signed by authorized officers of our suppliers, be submitted to us. At this time True Fresh HPP, LLLP does not engage in any third party verification but will continue to evaluate this process to see if it becomes necessary.

AUDIT
True Fresh HPP, LLLP does not currently conduct on-site announced or unannounced audits of suppliers to evaluate supplier compliance with company standards for slavery and human trafficking in supply chains, but will evaluate this process to see if it becomes necessary based on input from our suppliers, clients, government agencies and the public.

CERTIFICATION
True Fresh HPP, LLLP requires its direct suppliers to certify their compliance with all applicable laws, rules, regulations, orders, conventions, ordinances and standards that relate to anti-slavery and human trafficking in the country or countries that they do business in all aspects that relate to the manufacture and supply of products and services purchased. A letter confirming this compliance will be required from each supplier. All suppliers are aware that they must stay in compliance to continue to do business with True Fresh HPP, LLLP.

INTERNAL ACCOUNTABILITY
True Fresh HPP, LLLP should be made aware of any violation of our company standards regarding slavery and human trafficking by an employee or supplier in the manufacture or supply of products and services purchased. True Fresh HPP, LLLP will investigate any suspected case of non-compliance. If a non-compliant company is uncovered, we will provide written notice and a specified period of time to take corrective action. A non-compliant supplier that cannot, or will not, meet the requirements to become compliant within the time period provided will have its business relationship terminated. Any employee found to be non-compliant will face corrective action or termination.

TRAINING
True Fresh HPP, LLLP assures that company personnel responsible for supply chain management are knowledgeable regarding human trafficking and slavery and mitigating risks within supply chains.

We encourage employees, business partners and the public to communicate to us any concerns, questions, or issues they may have regarding supply chain slavery, supply chain human trafficking, or California Transparency in Supply Chains Act of 2010. Please direct any such communication to:

True Fresh HPP, LLLP
Attn: Supply Chain Transparency Vigilance
2525 Main Street, Suite 300
Irvine, CA 92614