Compliance with the California Transparency in Supply Chains Act

EP Minerals is a global leader in the production and supply of diatomite, clay, and perlite products and champions responsible corporate citizenship worldwide.

On January 1, 2012, California enacted the California Transparency in Supply Chains Act of 2010 requiring large manufacturers and retailers doing business in California to publicly disclose the actions they are undertaking to identify and eradicate forced labor and human trafficking in their supply chains.

EP Minerals is committed to fair labor practices throughout our global business activities. We support the California Act's goals of promoting supply chain transparency and accountability solutions. We understand the importance of providing our customers with information regarding our efforts to prevent slavery and human trafficking in our global supply chain.

EP Minerals has enacted a slavery and human trafficking policy that follows below and is also published in the EP Minerals Code of Business Conduct:

EP Minerals Anti-Slavery and Anti-Human Trafficking Policy

“EP Minerals is committed to ensuring, and requires its suppliers, agents, consultants, independent contractors, and representatives to ensure, that no form of forced or compulsory labor or trafficking of persons exists within our supply chain. EP Minerals will comply with, and requires its suppliers, agents, consultants, independent contractors, and representatives to comply with, all laws prohibiting any form of slavery, or practices similar to slavery, such as the sale and trafficking of persons, debt bondage, serfdom and forced or compulsory labor, including forced or compulsory recruitment for use in armed conflict, indentured or prison labor of any kind, or the employment of children under the minimum age established by local law."

Further, our actions in five key areas of supply chain transparency are as follows:

Verification of Product Supply Chain

EP Minerals commits to fostering responsible practices in our global supply chain. We support dedicated logistics and procurement departments that, on an ongoing basis without the use of third-party verification, internally evaluate the risks of human trafficking and slavery in EP's supply chain and strive to work only with reputable commodity suppliers. EP Minerals requires its suppliers to abide by the EP Minerals Code of Business Conduct which demands compliance with our Anti-Slavery and Anti-Human Trafficking Policy and all applicable federal and local laws in all the nations where we do business.

Supplier Audits

Auditing suppliers is a key element in managing our supply chain and we continually work toward confirming adherence by suppliers to our company standards. Our corporate policy states that EP Minerals will enter into representation or supplier agreements only with companies that have a demonstrated record of and commitment to the highest ethical standards. While we do not use third parties to conduct audits of our supplier's standards or their faithfulness to ours, we internally monitor our supply chain in an effort to confirm that our suppliers meet the standards required by our Code of Business Conduct which includes compliance with our Anti-Slavery and Anti-Human Trafficking Policy.

Certification

EP Minerals is developing a program that will ensure that direct suppliers to EP Minerals certify upon request that they are aware of our published Policy and the need to comply with federal and local laws preventing slavery and human trafficking. The program may be implemented either through the execution of supply agreements that contain such representations or through a certification process that will be monitored internally.

Internal Accountability

EP Minerals requires that all of its employees, agents, consultants, independent contractors, representatives and suppliers comply with the Code of Business Conduct which mandates that each party acts ethically and complies with our Anti-Slavery and Anti-Human Trafficking Policy. An EP Minerals corporate-wide organizational structure has been established to coordinate, implement and oversee compliance with the Code of Business Conduct and with the EP Minerals corporate policies, procedures and standards on which it is based. As with other alleged violations of law or policy, EP Minerals will investigate any issue brought to our attention regarding forced labor or human trafficking in our supply chain and will take appropriate action including termination of a business relationship with a supplier, employee, contractor, or representative in violation.

Training

All EP Minerals employees are provided the Code of Business Conduct and each employee must certify to the company that he/she has read and understood the responsibilities under the Code. Employees who fulfil procurement and supply-chain roles in our organization are specifically trained on a purchase order and supplier management process that exhibits a focus on adhering to the company's Anti-Slavery and Anti-Human Trafficking Policy and standards developed for selecting reputable and law-abiding suppliers.