California Transparency in Supply Chains Act

In January 2012, the California Transparency in Supply Chains Act went into effect. This California statute requires retailers and manufacturers to disclose “efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale.” SeaStar Solutions is an ethical enterprise and expects its employees and suppliers to engage in lawful and ethical business practices. The use of slave labor or human trafficking in the manufacture of SeaStar Solutions products or components supplied to the Company is unethical and unacceptable.

SeaStar Solutions expectations are that vendors manufacture and supply products in compliance with applicable laws, regulations and industry standards. This comprehensive expectation, demonstrates SeaStar Solutions commitment to lawful and ethical business practices, including labor practices.

SeaStar Solutions validates and approves its vendors based on a variety of criteria. SeaStar Solutions uses a variety of means to verify and evaluate its supply base. Vendor compliance with applicable laws, regulations and industry standards are among the items reviewed by the Company. SeaStar Solutions does not currently engage a third party in the supply chain verification process to specifically evaluate and address the risks of human trafficking and slavery.

The Company trains its employees in a variety of areas, including ethical business conduct.

The Company does not maintain internal accountability and procedures for employees or contractors related to failing to meet standards specifically regarding slavery and human trafficking. However, the Company maintains an ethics and compliance program which encourages reporting and is designed to identify and promptly address unethical or unlawful business practices, including labor practices.