California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act requires companies doing business in California to communicate their efforts in addressing the issues of human trafficking and slavery within their supply chains. The Act provides transparency to consumers and allows them to make informed choices about the products they buy and the companies they support. ABEO is opposed to human trafficking and slave labor practices and takes actions to protect its supply chains.

Verification

To evaluate compliance with our policies, including but not limited to compliance with the Company’s standards regarding human trafficking and slavery in supply chains, we internally verify our product supply chains. We utilize third party resources, as needed, to further evaluate specific supply chain risks.

Auditing

ABEO and its agents have the right and do conduct announced and unannounced inspections of the factories of its private label suppliers. Formal audits are performed by independent parties. In addition, trained members of our internal team monitor compliance with the Company’s standards regarding slavery and trafficking.

Certification

ABEO’s agreements with its manufacturers and agents require that ABEO’s suppliers do not engage in human trafficking or slave labor. ABEO may terminate the relationship with any supplier or agent who fails to meet its requirements.

Internal Accountability

In the event of a violation by a supplier of ABEO’s policy against human trafficking and slave labor practices, ABEO has the right to cancel outstanding orders and terminate future business with such supplier. Employees and contractors with sourcing and production responsibilities are expected to comply with ABEO’s policy against human trafficking and slave labor practices and any employee or contractor who acts in conflict with such policy will be subject to discipline, up to and including termination.

Training

Employees with direct responsibility for managing the supply chain receive training on reducing the risk of human trafficking and slavery in the supply chain.

Rev.11-19