California Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2010 (SB 657) requires companies doing business in California to post the extent to which they have taken certain specified actions to address the issues of slavery and human trafficking in their direct material supply chains.

Tinuum is committed to complying with all applicable laws and to conducting our business with integrity and high ethical standards. We require that our employees conduct themselves in accordance with this commitment, and expect our vendors and suppliers to do the same.

Given the nature of Tinuum’s business, we rely on a relatively small number of primarily U.S. suppliers with which we have tended to maintain long-term relationships. Accordingly, we believe our supply chain does not by its nature present a significant inherent risk of violations of slavery and human trafficking laws. While Tinuum recognizes and respects all labor and employment laws including those relating to slavery and human trafficking, at this point Tinuum does not engage in any specific procedures or requirements with respect to the areas enumerated by SB 657: (a) verification of product supply chains to evaluate and address the risks of human trafficking and slavery; (b) audit of suppliers to evaluate compliance with standards for human trafficking and slavery; (c) requiring direct suppliers to certify that all materials comply with laws regarding human trafficking and slavery; (d) maintaining internal accountability standards and procedures for employees and contractors who fail to meet company standards on human trafficking and slavery; and (e) providing systematic training on human trafficking and slavery to those involved in Tinuum’s supply chain.

Compliance with laws is part of the foundation of Tinuum, and the Code of Conduct requires all employees act with integrity and in compliance with laws applicable to our business. Tinuum takes seriously any potential violation of law related to our business operations and provides mechanisms for employees to report suspected violations to their supervisor, to the Tinuum General Counsel, or through our email compliance reporting system and telephonic compliance hotline.