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CA Transparency in Supply Chains

Introduction

ScottsMiracle-Gro, and its affiliates, comply with the California Transparency in Supply Chains Act.  This Act requires Companies to disclose information regarding their efforts to eradicate slavery and human trafficking from their supply chain. ScottsMiracle-Gro assesses risks in the supply chain and takes steps to mitigate the risk of human trafficking and forced labor in its supply chains through a number of processes, which may include verification, auditing, supplier certifications, internal accountability standards, and training and education.

Verification

In order to verify that ScottsMiracle-Gro supply chains do not use goods produced by forced labor, we monitor the U.S. Department of Labor’s updates specific to products and jurisdictions deemed to be high risk in this regard. Additionally, we have engaged a third-party partner to evaluate and “risk-rank” suppliers in our supply chain. This will be used to inform the Supplier Engagement Program, defined more fully below.

Auditing

The Supplier Engagement Program will consist of third-party audits, which could take one of many forms, which range from completion of a self-assessment questionnaire to an on-site audit, and everything in between. The third-party audits will help to verify the supplier’s conformity to the elements of the Supplier Code of Conduct and address any identified risks in timely, effective and efficient manners. The program will rely on a proprietary database that compiles information about our supply chain, including information provided by ScottsMiracle-Gro and information obtained through other sources.

Supplier Certification

Suppliers must adhere to the ScottsMiracle-Gro Supplier Code of Conduct, which can be found on our Company webpage, under Environmental, Social and Governance (ESG). The Supplier Code of Conduct states that “Supplier shall not support or engage in slavery or human trafficking in any part of its supply chain.” Additionally, our suppliers are contractually required to comply with all applicable federal, state and local laws, including but not limited to labor laws and laws related to forced labor, slavery and human trafficking in the country or countries in which it is doing business (collectively, the “Laws”).

Internal Accountability

If a supplier is found to be in violation of Laws or in violation of our Supplier Code of Conduct, ScottsMiracle-Gro will take action to address the situation, which could include termination of the relationship with the supplier.

Training and Education

Internal associates and managers involved in Supply Chain Management are provided education and training on the laws governing forced labor and human trafficking and how to mitigate risks associated with those activities.