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Standards for Suppliers

Henry Company understands the importance of encouraging its business partners to respect basic worker rights. Henry Company has adopted Standards for Suppliers that among other things states that suppliers are:

1. Expected to fully comply with all application nation and/or local laws and regulations, including those related to slavery and human trafficking; and

2. That labor should be voluntary.

Henry Co.’s Standards for Suppliers encourages the reporting of any alleged violations of those Standards to Henry Co.’s purchasing department. Substantiated, direct reports of violations by Suppliers of U.S. or foreign country laws relating to trafficking or slavery will be taken very seriously by Henry Co. in deciding whether to continue to do business with that Supplier.

The full text of the Henry Co. Standards for Suppliers is set forth here.

We are required by law to make certain specific disclosures regarding the company’s efforts to eradicate slavery and human trafficking from its direct supply chain that are set forth below.

Henry Co. does not engage in independent verification of its product supply chains to evaluate and address risks of human trafficking and slavery or conduct audits of suppliers to evaluate supplier compliance with those portions of its Standards of Suppliers regarding trafficking and slavery. Effective January 1, 2012, Henry Co. requires new suppliers entering into written purchase agreements with Henry Co., or existing suppliers entering into new written agreements, to certify that they have received, read and understand Henry Co.’s Standards for Suppliers. Henry Co. does not require direct suppliers to certify that materials incorporated into the products they provide comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business, however, as set forth in its Standards for Suppliers, Henry Co. does encourage it direct suppliers to ensure that materials incorporated into products supplied to Henry Co. comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Henry Co. has designated its Director of Global Purchasing as the person responsible for receiving reports of violations of Henry Co.’s Standards for Suppliers relating to human trafficking and slavery laws. Henry Co. employees who have direct responsibility for the supply chain (i.e., planners and buyers) have been asked to read and acknowledge receipt of the company’s Standards for Suppliers in effect as of January 1, 2012. Any knowing failures of Henry Co. buyers and planners to fail to report what they know to be a Supplier violation of the Standards relating to trafficking and human slavery will be punishable and considered in future compensation and promotion decisions.

While training has not occurred to date, Henry Co. intends to explore providing training on preventing human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products, to company employees and management who have direct responsibility for supply chain management, by April 2013.