California Transparency Act

California’s recently enacted Transparency in Supply Chain Act has raised valid concerns that all responsible manufacturers, including OPAL Nutrients LLC, are currently evaluating. Although OPAL Nutrients LLC would never knowingly conduct business with a supplier involved in slavery or human trafficking, the Company currently has no formal SOPs specifically addressing the issue. We employ no third–party verification or risk analysis of our supply chain, conduct no independent, unannounced audits with or require compliance certifications from our suppliers. We currently maintain no internal accountability standards for employees or contractors and provide no training regarding the risks of slavery and human trafficking in our supply chain. We are currently developing procedures to better ensure our supply chain is free from the abuses of slavery and human trafficking present in other parts of the world.