DISCLOSURES PURSUANT TO THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010
Universal Forest Products and its subsidiaries (collectively, “UFP”) make the following disclosures pursuant to the California Transparency in Supply Chains Act of 2010:
• Accountability. UFP complies with all applicable local, state, federal, and international laws, including those laws with respect to labor practices, human rights, slavery, and human trafficking and requires all of its employees and independent contractors to also comply with such laws. UFP also requires all of its employees to adhere to UFP’s Code of Business Conduct and Ethics. If UFP becomes aware that an employee or independent contractor does not adhere to applicable laws or the Code of Business Conduct and Ethics, such noncompliance will be addressed, and an investigation may be commenced depending on the circumstances. If allegations or concerns are substantiated, the employee or independent contractor will be disciplined, which may include a corrective action plan, termination, and/or delivering evidence to appropriate governmental authorities for prosecution.
• Training. UFP provides many internal and external training opportunities to its employees, including management, which opportunities may include supply chain transparency matters, including training on human trafficking and slavery issues and mitigation of risks within supply chains with respect to critical issues like human trafficking and slavery.
• Verification. UFP requires all of its suppliers to comply with all applicable local, state, federal, and international laws, including any laws regarding human trafficking and slavery. However, UFP does not currently engage in formal verification of its supply chains to specifically evaluate or address risks of human trafficking and slavery, nor does it use a third party in connection with any such analysis.
• Audits. UFP’s audits of its suppliers may be announced or unannounced and, although UFP has in the past (and may in the future) use a third-party auditor for its supply chain, it does not currently do so, nor do its current audits specifically address human trafficking and slavery.
• Certifications. UFP requires its suppliers to comply with all applicable local, state, federal and international law; however, it does not currently require its suppliers to certify that materials incorporated into their respective products comply with applicable laws regarding human trafficking and slavery of the countries in which they do business.
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