Supply Chain Transparency Disclosure

Gelson’s Markets conducts business in an ethical and lawful manner. On January 1, 2012, the California Transparency In Supply Chain Act (SB 657) went into effect which requires large manufacturers and retailers to disclose their efforts to eradicate slavery and human trafficking. This information allows our customers to make informed decisions about a product’s supply chain when purchasing goods.

Gelson’s Markets’ commitment to social responsibility addresses the following areas in our effort to eradicate slavery and human trafficking: verification, certification, accountability, training and audit.

I. Verification and Certification

Through our Vendor Commitment Agreement all Gelson’s vendors must verify that slavery and human trafficking is not used in their supply chain. In addition, all Gelson’s vendors must certify that any and all subcontractors do not use any form of slavery and human trafficking in their manufacturing process.

II. Training and Accountability

All employees directly involved in the purchasing of goods from vendors receive trainings on the Company’s Code of Ethics and Business Conduct. Other training components include awareness of slavery and human trafficking risks in the supply chain and identifying and mitigating those risks.

Gelson’s Markets maintains internal accountability standards and procedures for employees and/or vendors failing to meet company standards regarding slavery and human trafficking. It is management’s duty to enforce these standards and it is expected that all employees, vendors and subcontractors comply with these standards.

III. Audit

In the event that a vendor has violated the terms of the Vendor Commitment Agreement, the vendor will be subject to review by the Director of Purchasing and the Vice President to determine the continuance of business relationship. Gelson’s Markets does not regularly conduct audits directly, or through third parties, of vendors or vendor’s subcontract facilities to monitor ongoing compliance with Gelson’s Markets’ policy.

Revised 4/23/13