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Compliance of Laws

The Gill Corporation Transparency in Supply Chains Act Disclosure

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 went into effect in the State of California. The act requires certain retailers and manufacturers doing business in California, like The Gill Corporation, to disclose their efforts, if any, to address the issues of human trafficking and slavery, thereby allowing consumers to make better informed decisions about the products they buy. The following is The Gill Corporation's required disclosure under the Act:

1. Risk Assessment. At this point in time, The Gill Corporation does not engage in verification of product supply chains to specifically evaluate or address the risks of human trafficking and slavery. The Gill Corporation and its subsidiaries strive to achieve and maintain the highest possible standards of corporate integrity and ethical behavior. The Gill Corporation expects that its suppliers will conduct their businesses not only in a lawful manner but also in compliance with the same high standards of integrity and ethics. We expect our suppliers to not support, promote or engage in the practice of human trafficking or slavery and we require suppliers to comply with laws including those regarding human trafficking and slavery.
2. Auditing. At this point in time, The Gill Corporation does not audit its suppliers to evaluate compliance with laws concerning human trafficking and slavery. The Gill Corporation seeks to use only suppliers which it believes act in an ethical and responsible manner. The Gill Corporation evaluates its suppliers on many different criteria, such as quality, financial stability, compliance with laws and business history. The Gill Corporation reserves the right to terminate its relationship with any supplier if it believes that a supplier is unable or unwilling to address concerns that The Gill Corporation identifies.
3. Certification. In 2012, The Gill Corporation intends to implement a program whereby it will require suppliers to certify that the materials incorporated into the suppliers products comply with the laws regarding human trafficking and slavery of the countries in which they are doing business.
4. Internal Auditing. The Gill Corporation operates within an established code of business conduct and ethics which applies to all its employees, advisory committee and its business partners. All are expected to comply with all applicable laws and regulations, including, but not limited to, those related to human trafficking and slavery. The Gill Corporation encourages anyone that has witnessed or has knowledge of an illegal or unethical activity, consult with or report the incident to his or her supervisor, senior management, The Gill Corporation legal counsel, the Human Resource Department and/or the Chief Executive Officer. All reports of alleged violations will be investigated and if the investigation indicates that corrective action is required, The Gill Corporation will determine the appropriate steps to take, including discipline, dismissal and possible legal proceedings.
5. Procurement Training. Beginning January 1, 2012, The Gill Corporation will familiarize those who have direct responsibility for its supply chain management with how to identify human trafficking and slavery issues and, to the extent possible, mitigate such risks.