California Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2010 (SB 657) is designed to increase the amount of information made available by manufacturers and retailers regarding efforts to address the issue of slavery and human trafficking in their supply chains.

IPS Corporation has adopted a Supplier Code of Conduct which requires, among other things, that our suppliers ensure that they do not use forced or involuntary labor or engage in any form of human trafficking. Additionally, IPS’s Code of Business Conduct and Ethics sets forth our commitment to fair employment practices in every aspect of our business. All IPS associates are required to comply with all applicable laws, including those related to labor and employment, and are expected to report any known or suspected violations of such.

IPS is not aware of any information that would suggest that any of our suppliers engage in slavery or human trafficking. Accordingly, at this point, we do not take any specific measures to evaluate the risks of slavery or human trafficking in our supply chain; audit our suppliers or require our suppliers to provide a certification related to their compliance in this area; or provide training or maintain internal accountability standards relating thereto apart from the standards set forth in our IPS Code of Business Conduct and Ethics and Supplier Code of Conduct.

This disclosure applies to all consolidated IPS subsidiaries that are California taxpayers subject to the California Transparency in Supply Chains Act.