99 Ranch Market supports the goals of the California Transparency in Supply Chains Act of 2010 and strongly condemns any form of forced labor, slavery and human trafficking. We have and are in the process of undertaking efforts to ensure and verify the absence of forced labor and human trafficking in our supply chain. Our actions in this area include the following:

1. Risk Assessments

We are a member of the Food Industry Business Roundtable, a non-profit membership organization dedicated to driving improvements in ethical business practices in the retail food industry through industry education and government relations to actively provide a unified voice on critical issues affecting the retail food industry. We do not presently engage in geographic evaluations of our product supply chains to evaluate the risk of noncompliance in human rights and labor issues. However, it is our intent to establish a policy and/or utilize a third party auditor to conduct such verifications of our major suppliers.

2. Auditing

We perform extensive internal auditing of our Food Processing Center, Bakery Central Kitchen, and random on-site auditing of our major local suppliers that include food safety, product quality and social responsibility. The verification is not an independent unannounced audit.

3. Certification Requirements

We are in the process of requiring all our major suppliers to certify that they and the manufacturers of the products they sell to 99 Ranch Market do comply with applicable laws and regulations regarding slavery and human trafficking. This requirement will be incorporated into our supplier agreements.

4. Employee Standards of Conduct

We are committed to responsible and ethical conduct in the workplace. Our business practices have been governed by honesty, fair dealing, integrity and full compliance with applicable laws and regulations. All of our employees must adhere to our Employee Standards of Conduct, which requires compliance with all laws and regulations, including laws regarding slavery and human trafficking. Employees who violate the Employee Standard of Conduct may result in disciplinary action up to and including termination of their employment.

5. Employee Training

We are in the process of providing employee trainings regarding slavery and human trafficking to those who have direct responsibility for supply chain management.