MARK ZUNINO

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT



INTRODUCTION

Mark Zunino (Nolan Miller, LLC) and its affiliated companies supports the goals of the California Transparency in Supply Chains Act of 2010 (the “Act”) and strives to be a model example of human rights and fair labor practices throughout its business activities.

Mark Zunino chooses the best suppliers in its field who provide premium quality in both their products and services but also by way of their ethical, social and environmental approaches and beliefs. To this end, Mark Zunino chooses its suppliers based upon their ethics, honesty, and integrity in their business dealings, as well as the social and environmental principles by which they operate.

The implementation of the Act presents the opportunity for Mark Zunino to reaffirm its commitment to enforcing measures that fight against slavery and human trafficking.

As a responsible corporate actor, Mark Zunino has long since integrated standards of the Act into its daily business practices and how our suppliers are selected.

Mark Zunino’s actions in this area include the following:

VERIFICATION REQUIREMENTS FOR SUPPLIERS

Mark Zunino has implemented the Mark Zunino Code of Conduct (the “Code”) and requires all suppliers (including their subcontractors involved with the manufacturing procedure for Mark Zunino’s products) to agree to and adhere to the terms of the Code. The Code sets forth and establishes non-negotiable minimum standards for Mark Zunino’s suppliers in the areas of health and safety, labor standards, business integrity, and the environment. In addition, Mark Zunino may conduct supplier audits, described below, in order to verify that its suppliers are complying with the Code.

SUPPLIER AUDITS

Mark Zunino audits suppliers that, based upon an analysis of the volume of the supplier’s business and the risk of abuses in the country in which the supplier is located, pose a high risk of working condition violations to ensure that its suppliers are compliant with Social Accountability International’s SA8000 standards, an international standardized code of conduct for improving working conditions around the world, and are compliant with the Code.

CERTIFICATION OF SUPPLIER COMPLIANCE

Mark Zunino requires its suppliers to sign and to adhere to the Code.

MAINTAINING ACCOUNTABILITY

In the event Mark Zunino becomes aware of any actions or conditions not in compliance with the Code, Mark Zunino reserves the right to demand corrective measures as well as the right to terminate an agreement with any supplier who does not comply with the Code.

TRAINING TO COMPANY EMPLOYEES

Mark Zunino and its employees endeavor to respect the laws and regulations in all countries in which they operate, and conducts its business according to principles outlined in the International Labour Organization and the United Nations Universal Declaration of Human Rights.

Mark Zunino will continue to evolve and adapt its policies and procedures to a changing world in order to reflect Mark Zunino’s unwavering commitment to ethical business principles.