The California Transparency in Supply Chains Act Disclosure

Russell Stover Chocolates, LLC, a member of the Lindt & Sprüngli group, strongly condemns human trafficking and slavery and remains committed to ensuring that our supply chains are free from human trafficking and slavery.

The Lindt & Sprüngli Supplier Code of Conduct ("Supplier Code of Conduct") helps to implement this commitment in our supply chains. The Supplier Code of Conduct demands our suppliers to comply with all applicable national and international laws and regulations relating to human trafficking and slavery, including the International Labour Organization and the United Nations' Universal Declaration of Human Rights.

Russell Stover Chocolates' standard purchase order expressly states:

"Russell Stover will not tolerate the use of child labor in the manufacture of articles, goods or products it sells nor will it accept articles, goods or products from vendors that use in any manner child labor in their contracting, subcontracting or manufacturing. The definition of child will first be derived from the national laws of the country in which the vendor is doing business. If the laws of that country do not provide such a definition or the definition includes only individuals under the age of 15, Russell Stover will define "child" for the purpose of determining use of illegal child labor as anyone who is less than 15 years of age or younger than the compulsory age to be in school in the country in which the vendor is doing business, if that age is higher than 15. Russell Stover does support legitimate workplace apprenticeship education programs for younger persons. Seller will not use child labor in any manner in its contracting, subcontracting or manufacturing."

Additionally, Russell Stover Chocolates requires each of its suppliers to represent that any goods delivered under a Russell Stover purchase order comply with all applicable laws and regulations, which includes all prohibitions against child labor and slavery.

Verification

Under our purchase order, we retain the right to refuse any shipment of product, or to return defective or non-conforming product where such product is made by the use of human trafficking and slavery as well as prohibited child labor. In our Supplier Code of Conduct, we require that our supplier partners adopt sustainability measures.

Audits

Under our Supplier Code of Conduct, we reserve the right to conduct (or have a third party conduct) audits of suppliers and their facilities to verify compliance with the Supplier Code of Conduct. Suppliers we define "at risk" for noncompliance with any aspect of our Supplier Code of Conduct, including the requirements related to human trafficking and slavery, can be assessed, audited and/or verified by independent parties.

Certifications

Under the Supplier Code of Conduct our suppliers confirm that they: (1) have received and commit to fully comply with our Supplier Code of Conduct Code and its principles and requirements; (2) agree that we or a third party may carry out periodic, audits on their facilities; and (3) effectively communicate the contents of our Supplier Code of Conduct to their employees, agents, subcontractors and suppliers and ensure all measures required are implemented accordingly. Failure to comply with the requirements set out in our Supplier Code of Conduct may result in Russell Stover Chocolates ceasing to do business with offending suppliers.

Accountability

All Russell Stover Chocolates employees are required to adhere to the Lindt & Sprüngli Business Code of Conduct, which includes compliance with all laws and regulations. The CEO of Russell Stover Chocolates is responsible for ensuring that employees are informed and educated about the Business Code of Conduct. Furthermore, the CEO is expected to enforce strict adherence to the rules and regulations of the policy. Our disciplinary policy permits a range of measures, from corrective actions up to termination of relationships with employees involved in any misconduct.

Training

Relevant employees receive training on the relevant portions relating to sustainable development.