CA Transparency Act

The California Transparency in Supply Chains Act of 2010

Bio-Nutritional Research Group, Inc. (“BNRG”) is providing this statement about its obligations under the California Transparency in Supply Chains Act of 2010 (the “Act”). The Act requires BNRG to publicly disclose its efforts to eradicate slavery and human trafficking from its direct supply chain. Human trafficking is a form of forced and compulsory labor. In accordance with the Act, this initial statement articulates our current policies and practices around recognizing and preventing human trafficking and slavery in the global supply chain and programs BNRG will be implementing in its future.

We adhere to all state and federal employment and labor laws.  Accordingly, we do not engage in the use of forced, bonded, indentured, or involuntary labor and do not tolerate our suppliers engaging in such conduct should we learn of it. BNRG expects its suppliers to comply with legal requirements and operate consistently with the principles of BNRG when working on our behalf, and our contracts require suppliers to certify that they comply with all applicable laws, regulations, and ordinances. In maintaining our internal accountability standards and commitment to comply with the Act, BNRG will terminate supplier contracts when a serious breach by a supplier is found to have occurred.

Further, given BNRG’s commitment to comply with the values espoused in the Act and its insistence on promoting fair labor practices throughout every aspect of its organization, BNRG is continuing to evaluate its supply chain practices and procedures to determine where it can bolster its compliance. While BNRG does not currently have a formal verification program and does not employ third parties to verify supplier compliance, BNRG is actively engaged in evaluating verification procedures for its suppliers to ensure that they comply with BNRG’s expectations for clean supply chains. BNRG has not performed any social responsibility audits, either internally or through a third-party audit, in relation to the Act to this point in the Company’s history. Although not currently in place, BNRG is working towards providing a training program on human trafficking and slavery—particularly with respect to mitigating risks within the supply chains of products—to employees who have direct responsibility for supply chain management.