California Transparency in Supply Chains Act of 2010

Kelly-Moore Paint Company, Inc.

Policy Statement for CA Transparency in Supply Chains Act of 2010

It is the policy of Kelly-Moore Paint Company, Inc. (KMPC) to make reasonable efforts to ensure that our supply chain is free of any products of forced labor, child labor, human trafficking and slavery. To that end, KMPC has undertaken the following:

(1)            KMPC has investigated and evaluated the potential for products of forced labor, child labor, human trafficking and slavery to be present in its direct supply chain. We find that the raw materials used in the manufacture of architectural coatings are not known to be associated with any inhumane labor practices. It should be noted that architectural coatings raw materials are not among the products listed in U.S. Department of Labor’s 2009 Report on the List of Goods Produced by Child Labor or Forced Labor. Further, the American Coatings Association, the principal trade association for the U.S. paint and coatings industry, is not aware of any documented instances of these labor practices in the industry or its supply chain. With respect to the sundry items sold but not manufactured by KMPC, we find no indication that our direct suppliers engage in any inhumane labor practices.

(2)            If, at any time, KMPC should become aware of any credible indication of potential inhumane labor practices on the part of a direct supplier, KMPC will arrange to conduct an independent, unannounced audit of that supplier to the extent practicable.

(3)            KMPC has begun to require its direct suppliers to certify in writing that materials incorporated into their products comply with the laws regarding forced labor, child labor, human trafficking and slavery in the country or countries where they do business.

(4)            KMPC maintains internal accountability standards for employees or contractors failing to meet company standards regarding avoidance of forced labor, child labor, human trafficking and slavery.

(5)            KMPC provides company employees and management, who have direct responsibility for supply chain management, training on forced labor, child labor, human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.