Corporate Disclosure in Compliance with
SB 657 California Transparency in Supply Chains Act
(Human Trafficking and Slave Labor)

In 2010, California passed a law requiring companies to disclose their efforts to eliminate human trafficking and slave labor from their supply chains. Referred to as SB 657, the California Transparency in Supply Chains Act of 2010 seeks to "educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains to improve the lives of victims of slavery and human trafficking."


Nutrition Now, Inc. ("NNI") is a U.S. based manufacturer that thrives on change and adapts to evolving economic, social, and environmental conditions for a better future. We do not condone human trafficking or slave labor, and we acknowledge that these are worldwide problems that are not limited to a specific age, sex, or region. We strive to have a strong, positive, impact on the health and well-being of people throughout the world. With these principles in mind, we formalized our Supplier Code of Conduct which details our guidelines regarding employment, environment, and ethical business practices.

Verification:

NNI complies with U.S. federal and state laws including those related to lawful labor practices. We strive to maintain a healthy, respectful, challenging, and rewarding environment for our employees. To that end, we use only voluntary labor and prohibit the use of child labor and participation in human trafficking. In addition, our Supplier Code of Conduct requires use of only voluntary labor and prohibits child labor and participation in human trafficking.


We continually review and update our internal policies and procedures to ensure that they adequately address fair and ethical labor practices, including prohibitions on slavery and human trafficking. Although it is our policy to purchase from reputable, U.S. based companies, we will continue to evaluate our product supply chain to assess and address risks of human trafficking and slavery. As appropriate, we may engage a qualified third party to assist in mapping our supply chain and assessing risk areas.

Auditing:

NNI audits suppliers annually for compliance with current Good Manufacturing Practices for dietary supplements. NNI requires suppliers to disclose all facilities producing products for us. These facilities are required to adhere to our Supplier Code of Conduct. As appropriate, based on our supply chain risk assessment, certain suppliers may be subject to more frequent audits based on defined standards addressing slavery and human trafficking. Audits may be either unannounced or pre-arranged, by a qualified third party and/or by our in-house auditors. Such audits would include on-site factory inspection and confidential interviews with employees and, where applicable, on-site contract workers.


Upon completion of an audit, the identified issues and recommendations to rectify violations observed would be discussed and documented with the audited facility. Factory management would be expected to address all identified issues as noted.

Certification:

NNI requires all suppliers to certify their compliance with our Supplier Code of Conduct, which includes compliance with the laws regarding slavery and human trafficking in the country or countries in which they are doing business.

Internal Accountability:

NNI maintains internal accountability standards for our own compliance with U.S. federal and state laws including those related to lawful labor practices. We hold suppliers accountable for compliance with our Supplier Code of Conduct. If we discover a violation of our Supplier Code of Conduct, we will work with the supplier to remedy the violation, uphold workers’ rights and improve the overall workplace environment. If a supplier fails to correct a violation, it will jeopardize our relationship with that supplier, up to and including termination of the relationship.


Our senior leadership will have direct involvement and accountability for monitoring and ensuring compliance with the Supplier Code of Conduct. Periodic reports regarding supplier compliance with the Supplier Code of Conduct will be provided to our senior leadership.

Training:

NNI is in the process of expanding the scope of training on human trafficking and slavery to employees, contractors, and management who have direct responsibility for supply chain management, particularly with respect to identifying, mitigating, and eliminating risks within the supply chain.