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California Transparency in Supply Chains Act Disclosure Statement

The California Transparency in Supply Chains Act of 2010 (SB 657) “Act” became effective January 1, 2012 in the State of California.  The Act requires that certain companies doing business in California disclose their efforts to eliminate slavery and human trafficking from their direct supply chains.

Fort Wayne Metals recognizes the importance of making efforts to ensure that our supply chain is free of any products of human trafficking and slavery.  We are therefore in the process of implementing policies and procedures in an effort to ensure, to the extent practicable, that our direct supply chain is free of products of human trafficking and slavery.

Fort Wayne Metals has always expected that all of its suppliers abide by any applicable laws, rules and regulations, including those addressing human trafficking and slavery.

1. We source our raw materials from reputable suppliers in the US, Europe and developed countries, which pose a low risk of human trafficking and slavery.  As such, we currently do not have a formal process or use a third party for verification of the supply chain.

2. Although we conduct supplier audits where working conditions could be viewed, the audits do not specifically evaluate compliance with company standards for human trafficking and slavery in supply chains.

3. As we perceive the risk of our supply chain using products of human trafficking and slavery to be low, we do not currently obtain certification from our suppliers that materials incorporated into our products comply with the laws regarding slavery and human trafficking. We are working towards a system that will require certain suppliers, depending upon the commodity purchased, geographic location, and other relevant criteria, to provide this documentation in the future.

4. We require all of our employees to follow applicable laws and policies.  As we are in the process of implementing policies and procedures regarding the evaluation of the supply chain, we are also developing internal accountability standards and procedures for employees and contractors related to same.

5. We will develop and conduct training on slavery and human trafficking for our employees and managers who have direct responsibility for supply chain management in the near future.

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