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Hamilton Supply Chain Disclosure


Hamilton is required by the “California Transparency in Supply Chains Act” to identify and disclose its efforts to engage in conduct, as directed by the Act, to eliminate slavery and human trafficking from within its direct supply chains.  This disclosure is being made to comply with California law.

Hamilton takes seriously all efforts to erase all kinds of forced labor.  This is established at Hamilton through a desire to bring properly sourced materials to market through standards set forth in our internal processes and procedures as established by Hamilton Company, and adopted by affiliated companies.

SUPPLY CHAIN VERIFICATION AND AUDIT
Hamilton’s policy is to evaluate potential contracted factories before they enter the supply chain to assess compliance with standards including country-related risk for issues including forced labor, human trafficking and slavery.  Hamilton attempt’s to conduct internal audits of suppliers from time to time, but has not engaged an outside auditor to validate the audited information.

DIRECT SUPPLIERS' CERTIFICATION OF MATERIALS

Hamilton is working on understanding impacts further up the supply chain, to develop standards for upstream suppliers of contracted manufacturers.  At present, there are no stated guidelines internally for qualification and certification of suppliers.

STANDARDS FOR COMPLIANCE
If a contracted factory is found to violate laws or Hamilton standards, Hamilton will require compliance of the third party and will direct that such violation of law or internal standards be rectified, leaving the violating entity responsible for improving performance against a master action plan or corrective action plan.  If the factory fails to make progress against that plan, they are subject to review and sanctions, including potential termination.

TRAINING
Employees and management with direct responsibility for supply chain management have been provided notification of and information regarding forced labor, including human trafficking and slavery.