As of January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) is effective in the State of California. As a result, many companies manufacturing or selling products in California are required to disclose their efforts (if any) to address the issues of human trafficking and slavery, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Cornerstone Specialty Products, LLC. endeavor to achieve and maintain the highest possible standards of corporate integrity and ethical behavior. CSP Dental takes the issues of slavery and human trafficking very seriously and will continue doing its part by responsibly managing its supply chains in an effort to eradicate human trafficking and slavery. CSP Dental makes the following disclosures required by Section 1714.43(c) of the California Civil Code:

Verification
CSP Dental expects that its suppliers will conduct their businesses not only in a lawful manner but also in compliance with high standards of integrity and ethics. In order to establish guidelines for such standards, CSP Dental has established a Supplier Code of Conduct which is distributed to CSP Dental suppliers. The Supplier Code of Conduct requires supplier compliance with important legal and ethical requirements. Specifically, the Supplier Code of Conduct states that suppliers must not support, promote or engage in the practice of slavery or human trafficking.

CSP Dental suppliers are further expected to take reasonable and necessary steps to help ensure that their subcontractors and sub-suppliers conduct business in compliance with the Supplier Code of Conduct. Suppliers are expected to promptly take corrective action to address any deficiencies identified with respect to compliance with CSP Dental’ Supplier Code of Conduct.

In the Supplier Code of Conduct, Slavery, Human Trafficking and Child Labor are specifically called out as activities for which CSP Dental has a zero tolerance policy. If a supplier is found to be in violation of the Supplier Code of Conduct, CSP Dental will take prompt, remedial measures to address the violation. CSP Dental reserves the right to terminate its relationship with any supplier for failure to comply with this Supplier Code of Conduct.

Audits
CSP Dental does not currently have a specific policy or process requiring specific or routine audits to evaluate compliance with company standards for trafficking and slavery in supply chains. To the extent CSP Dental suspects or receives notice that a supplier is involved in prohibited activities, CSP Dental will conduct an inquiry, or third-party audit if warranted, and take appropriate action as required by law.

Certifications
CSP Dental requires its suppliers to certify the acceptance of the “CSP Dental Supplier Code of Conduct” by the act of supplying any goods or services to CSP Dental and certifying that the materials incorporated into the supplier’s products comply with the laws of the country or countries in which they are doing business.

Accountability
CSP Dental has established an Employee Code of Business Conduct, which applies to all CSP Dental personnel (collectively, “Employees”). CSP Dental expects its business partners and contractors to share the general principles stated in the Code of Business Conduct. These general principles require CSP Dental Employees to comply with all applicable laws and regulations, including but not limited to those relating to human trafficking and slavery. The Code of Business Conduct explains that if an Employee needs guidance on a legal or ethical question or has witnessed or has knowledge of an illegal or unethical activity, he or she should consult with or report the matter to their manager, supervisor or Human Resources, depending on the specific circumstances. All reports of alleged violations will be investigated by CSP Dental. Deliberate ignorance of the law is not tolerated and may lead to disciplinary action.

Training
All employees are required to read and acknowledge the Code of Business Conduct. The Code of Business Conduct requires CSP Dental Employees to comply with all applicable laws and regulations, including but not limited to those relating to human trafficking and slavery. Employees that have direct responsibility for supplier management are also trained to the CSP Dental Code of Conduct. The Supplier Code of Conduct, informs suppliers that CSP Dental will take prompt, remedial measures to address the violation.