California
Transparency

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

Arbor Pharmaceuticals, LLC is committed to fair labor practices within our supply chain. We therefore engage a third-party monitor who uses a multi-level process to identify and evaluate the potential risks for human trafficking and slavery in our supply chain. Prior to partnering with any new suppliers, and randomly thereafter, our monitor conducts an initial screening of those suppliers. The monitor’s evaluation of human trafficking risks is based on a variety of factors. Any high risk suppliers are assessed and monitored as needed.

We conduct assessments of our product suppliers to verify that they are not at risk for violating anti-slavery and human trafficking laws. We do not use third-party verifiers. Our own risk-management team spearheads the verification process using an internally developed rubric and multi-part assessment. Our risk-management team is currently unable to verify whether our subcontractors use labor brokers.

Our internal auditing team conducts audits of our direct suppliers to evaluate their compliance with our anti-slavery and human trafficking company standards. Audits consist of individual and group interviews with supervisors and management, as well as exhaustive facility tours.

Currently, we do not require our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business.