CALIFORNIA TRANSPARENCY ACT DISCLOSURE

DISCLOSURES REQUIRED PURSUANT TO THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

Hydronix Water Technology, LLC (“Hydronix”) is a signatory to the United Nations Global Compact and is committed to promoting socially responsible conduct that aligns to the 10 universally accepted principles, including those related to human rights and labor: (4) the elimination of all forms of forced and compulsory labor and (5) the effective abolition of child labor. These principles are woven throughout The Diamond Standard — Hydronix Code of Business Conduct (the “Code”). All employees of Hydronix and its subsidiaries, including those with direct responsibility for supply chain management, are expected to know and abide by this Code. Rigorous training on the content and application of the Code is mandatory for each and every employee, and each employee must periodically acknowledge that they have read and agree to comply with the Code. Hydronix takes seriously and fully investigates all potential legal or Code violations, in a respectful, confidential and fair manner. When an allegation of an employee Code violation is substantiated, an appropriate management team is convened to review the investigation findings and determine a final outcome. Consistent with the severity of the violation, discipline can include verbal or written warning, suspension with or without pay, loss or reduction of bonus or stock options, demotion or, for the most serious offenses or repeated misconduct, employment termination. Hydronix’s Code states:

Respect for human rights and dignity is a cornerstone of our business.

  • We do not use forced or involuntary labor.
  • We comply with all applicable child labor laws.

Among other things, the Hydronix Water Technology Supplier Code sets forth expectations with respect to Human Rights and Labor:

  • No Forced and Compulsory Labor: Suppliers will not use forced or involuntary labor, including prison labor, indentured labor, bonded labor or slave labor.
  • No Harassment and Abuse of Labor: Suppliers will ensure that their employees are not subjected to psychological, verbal, sexual or physical harassment or to any form of abuse, and will comply with all applicable laws on harassment and abuse of employees.
  • No Child Labor: Suppliers will comply with all applicable child labor laws.

The Supplier Code also details Hydronix’s expectations concerning Suppliers’ systems and procedures to ensure compliance for itself and for its suppliers, and the potential consequences of non-compliance:

Compliance: Hydronix expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Code, including policies, training, monitoring and auditing mechanisms. Suppliers also should apply these or similar principles to the subcontractors and suppliers they work with in providing goods and services to Hydronix. Hydronix reserves the right to assess and monitor suppliers’ compliance with this Code. Suppliers who are not in compliance with this Code are expected to implement corrective actions or may not be considered for future business.