In this Section:

Terms of Use – Privacy Policy – CA Supply Chains Act

 Terms of Use

This Terms of Use Agreement governs the website located at https://lassondepappas.com which is owned by Lassonde Pappas and Company, Inc. (“Lassonde Pappas”, “we”, “us” or “our”, as appropriate). Before you visit or become a user of our website, you must read and accept all of the terms and conditions in this Terms of Use Agreement and of our Privacy Policy.

1. Proprietary Rights
You acknowledge and agree that Lassonde Pappas (or Lassonde Pappas’s licensors) own all legal right, title and interest in and to the website, including any intellectual property rights which subsist in the website (whether those rights happen to be registered or not, and wherever in the world those rights may exist). Nothing in the Terms of Use Agreement gives you a right to these rights or to use any of Lassonde Pappas’s trade names, trademarks, service marks, logos, domain names, and other distinctive brand features. You may electronically copy and print hard copies of pages from this website for your personal or professional use provided that reference is made to Lassonde when the document is used. Aside from the foregoing, you may not reproduce, publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of, or exploit in any way this website or any of its content including corporate, media, stock market and other information, material, data, text, software, music, sound, photographs, graphics and video included in such content (“Content”).
2. Responsibility for Lassonde Pappas Content
Although reasonable efforts are used to ensure that this website will be current and accurate, we do not represent or warrant that this website will be error free, or completely accurate or current at all times or at any time. We may make available various Content on our website. The Content on this website is for informational purposes only. We do not guarantee the accuracy, integrity or quality of any Content made available on our website and except as otherwise provided for in this Terms of Use Agreement, Content is available on as “as is” basis. You therefore agree that you will not hold Lassonde Pappas responsible or liable for any inaccuracies in the Content posted, for any errors or omissions in any Content, or for any loss or damage of any kind incurred as a result of the use of or reliance upon any Content posted, emailed, transmitted, or otherwise made available via our website.
All press releases and all investor relations information on the website provided by Lassonde are provided for informational purposes only and Lassonde does not warrant the accuracy of such documents after the date of posting. Certain statements posted on the website contain forward-looking information within the meaning of applicable securities laws (“forward-looking statements”). Such forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause the actual results, performance or achievements of Lassonde Pappas, or developments in Lassonde Pappas’s business or in its industry, to differ materially from the anticipated results, performance, achievements or developments expressed or implied by such forward-looking statements. Forward-looking statements include all disclosure regarding possible events, conditions or results of operations that is based on assumptions about future economic conditions and courses of action. Forward-looking statements may also include, without limitation, any statement relating to future events, conditions or circumstances. Lassonde Pappas cautions you not to place undue reliance upon any such forward-looking statements, which speak only as of the date they are made. Forward-looking statements are based on management’s current plans, estimates, projections, beliefs and opinions and assumptions related to these plans, estimates, projections, beliefs and opinions may change. The information contained on the website is subject to change and Lassonde Pappas reserves the right to change or remove any Content from the website, in whole or in part, at its sole discretion, at any time, without notice. Section 10 of this Terms of Use Agreement provides additional details on the limited liability of Lassonde Pappas.
3. Responsibility for Partners’ Content
Certain of our partners such as suppliers, health experts or sports celebrities may post or make available Content on our website. This may include health or nutrition related tips and advice. These partners may also share their life experience or their experience in connection with the use of our products. You understand that Lassonde Pappas is making this Content available to you for informational purposes only and that given that these partners are speaking under their own name and in light of their respective expertise, you acknowledge and agree that Lassonde Pappas does not endorse and is not responsible or liable for such partners’ Content, and that Lassonde Pappas is not responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such partners’ Content, advertising or products.
4. External Links
Our website may link to or provide links to other websites or content or resources. Lassonde Pappas has no control over such third party’s websites and resources. You acknowledge and agree that Lassonde Pappas is not responsible for the availability of such external websites or resources, and does not endorse and is not responsible or liable for any Content, advertising, products, or other materials on or available from such websites or resources. You further acknowledge and agree that Lassonde Pappas is not responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such Content, goods or advertising, products, or other materials on or available from such websites or resources.
5. Content License from You
Lassonde Pappas may make available a Web-based Message Board, which can be used by website users to post Content. When you send, submit, post or display Content through our website, you retain copyright and any other rights you already hold in such Content. By sending, submitting, posting or displaying any Content when using our website or through our website, you grant us a perpetual, irrevocable, worldwide, royalty-free, and non-exclusive license (through multiple tiers) to reproduce, adapt, modify, translate, publish, publicly perform, publicly display and distribute such Content. You confirm and warrant to Lassonde Pappas that you have all the rights, power and authority necessary to grant the above license.
6. Responsibility for User Content
You understand that all Content, whether publicly posted or privately transmitted when sending, submitting or posting Content when using our website (such as when using the Web-based Message Board), is the sole responsibility of the person from which it originated. This means that you are entirely responsible for all Content that you upload, post, email, transmit, or otherwise make available via our website, for instance through the Web-based Message Board and for ensuring that all Content pertaining thereto are accurate and do not include misleading information and in no way infringe or violate anyone’s proprietary rights. More specifically, you agree that you will not use our website to:
• violate any laws or third party rights;
• use our website if you are temporarily or indefinitely suspended from our website, or if you are under the age of 18 unless your parent or legal guardian provides its consent to your use of our website, and agrees to be bound by this Terms of Use Agreement in respect of your use of the website;
• upload, post, email, transmit, or otherwise make available any Content that: (i) is false, inaccurate, misleading, defamatory, libelous, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, invasive of another’s privacy, hateful, racially, ethnically or otherwise objectionable or generally unlawful; (ii) you do not have a right to make available under any law or under contractual or fiduciary relationships; (iii) infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; (iv) would constitute unsolicited or unauthorized advertising, promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of illegal solicitation;
• impersonate any person or entity, including, but not limited to, a Lassonde Pappas official, falsely state or otherwise misrepresent your affiliation with a person or entity, forge headers or otherwise manipulate identifiers in order to disguise the origin of any Content that you post or transmit through our website;
• distribute viruses or any other technologies that may harm our website, or the interests or property of our website’s users;
• copy, modify, or distribute Content from our website and Lassonde Pappas’s copyrights and trademarks; or
• harvest or otherwise collect, use or disclose personal information about users, including email addresses, without their prior consent or not in compliance with applicable data protection and privacy laws.

7. Right to Remove or Disclose Content
You acknowledge that Lassonde Pappas does not pre-screen Content, but that Lassonde Pappas has the right (but not the obligation) to refuse or remove any Content that is available via the website or the Web-based Message Content that violates this Terms of Use Agreement or is otherwise objectionable in its discretion. You acknowledge and expressly consent to Lassonde Pappas accessing, preserving, and disclosing your personal information and Content if required to do so by law or if in good faith it believes that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce this Terms of Use Agreement; (c) respond to claims that any Content violates the rights of third-parties; (d) respond to your requests for customer service; or (e) protect the rights, property, or personal safety or security of Lassonde Pappas, its website, its users and the public.
8. Practices Limits Concerning Use of the Web-based Message Board
You acknowledge that Lassonde Pappas may establish general practices and limits concerning the use of the Web-based Message Board of its website, including without limitation the maximum number of days that messages or other uploaded Content will be retained by the website, the maximum number of postings that may be uploaded by a user, the maximum size of any message that may be uploaded by a user, and the maximum number of times (and the maximum duration for which) you may access or use the Web-based Message Board in a given period of time. You further acknowledge that Lassonde Pappas reserves the right to change these general practices and limits at any time, in its sole discretion, with or without notice.
9. Access to Media Information or other Content
Upon requesting access to certain Content available on our website such as Lassonde Pappas’s media information, you may be asked to identify yourself, provide contact information such as your email address and specify the purpose or intended use of the information. You agree to provide true, accurate, current and complete information about yourself as prompted by the website form and maintain and promptly update this data to keep it true, accurate, current and complete at all times. You agree to immediately notify Lassonde Pappas of any unauthorized use of your personal information or any other breach of security involving your information.
10. Termination of Use
Without limiting other remedies, Lassonde Pappas may in its sole discretion, limit, suspend, or terminate your use of the website, prohibit access to its website, and take technical and legal steps to keep users off its website, remove and discard any user Content within the website, for any reason, including, without limitation, (a) if Lassonde Pappas believes that you have violated or acted inconsistently with the letter or spirit of this Terms of Use Agreement; (b) request(s) by law enforcement or other government agencies; (c) if you provide any information that is untrue, inaccurate, not current or incomplete in your request to access Lassonde Pappas’s media information, or Lassonde Pappas has reasonable grounds to suspect that you have done so; (d) discontinuance or material modification to the website (or any part thereof); (e) unexpected technical or security issues or problems; (f) in compliance with legal process; and/or (g) if you have or we believe you have engaged in illegal activities, including without limitation, fraud or in noncompliance with applicable data protection, anti-spam and privacy laws.
You acknowledge and agree that any termination of your access to the website under any provision of this Terms of Use Agreement may be effected without prior notice, and that Lassonde Pappas may immediately delete your Content. You agree that Lassonde Pappas is not liable to you or any third-party for termination of your access to the website. The sections of this Terms of Use Agreement which by nature should survive the termination of this Terms of Use Agreement will do so.
11. Limitation of Liability
You will not hold Lassonde Pappas responsible for actions or inactions, which are made through our website or using our website. We cannot guarantee the secure access to our website, and operation of our website may be interfered with by numerous factors outside of our control. To the extent permitted by law, neither Lassonde Pappas nor any of its divisions, partners, directors, officers, employees, agents, successors or assigns shall be liable for any damages whatsoever arising out of or related to access to, or use of, this website, including, without limitation, liability for direct, indirect, special, incidental or consequential damages, whether or not Lassonde Pappas was advised, knew or should have known of the possibility of such damages.
TO THE EXTENT PERMITTED BY LAW, YOU EXPRESSLY UNDERSTAND AND AGREE THAT LASSONDE PAPPAS AND ITS LICENSORS AND PARTNERS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, WHICH MAY BE INCURRED BY YOU, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY. THIS SHALL INCLUDE, BUT NOT BE LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL OR BUSINESS REPUTATION, ANY LOSS OF DATA SUFFERED, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR OTHER INTANGIBLE LOSS (EVEN IF LASSONDE PAPPAS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), RESULTING FROM THE USE OR THE INABILITY TO USE THE WEBSITE OR ANY MATTER RELATING TO THE WEBSITE INCLUDING WITHOUT LIMITATION (I) ANY CHANGES WHICH LASSONDE PAPPAS MAY MAKE TO THE WEBSITE, OR FOR ANY PERMANENT OR TEMPORARY CESSATION IN THE PROVISION OF THE WEBSITE (OR ANY FEATURES WITHIN THE WEBSITE); (II) THE DELETION OF, CORRUPTION OF, OR FAILURE TO SEND, DISPLAY OR STORE, ANY CONTENT AND OTHER COMMUNICATIONS DATA MAINTAINED OR TRANSMITTED BY OR THROUGH YOUR USE OR OTHER USERS USE OF THE WEBSITE.
12. Release and Indemnity
If you have a dispute with one or more users, you release us and our licensors (and our officers, directors, agents, subsidiaries, joint ventures and employees) from claims, demands and damages (actual and consequential) of every kind and nature, known and unknown, arising out of or in any way connected with such disputes. You agree to indemnify and hold Lassonde Pappas and its licensors (and our officers, directors, agents, subsidiaries, joint ventures, partners and employees), harmless from any claim or demand, including reasonable legal fees, made by any third party due to or arising out of your breach or violation of this Terms of Use Agreement, of any Content which you submit, post, transmit or make available through the website or the Web-based Message Board, your use of the website, your connection to the website, or your violation of any rights of another or your violation of any law or the rights of a third party.
13. Privacy
We use your personal information only as described in our Privacy Policy which is part of and is hereby incorporated into this Terms of Use Agreement. If you object to your personal information being transferred or used in the way referred to in our Privacy Policy, please do not use our website.

14. No Agency
No agency, partnership, joint venture, employee-employer or franchiser-franchisee relationship is intended or created by this Terms of Use Agreement.
15. Law and Forum for Disputes
The laws of the State of Delaware shall apply to the interpretation of this Terms of Use Agreement notwithstanding any conflict of law provisions. All proceedings relating to the website or to this Terms of Use Agreement shall be brought before the courts of the State of Delaware.
16. General
If any provision of this Terms of Use Agreement is held to be invalid or unenforceable, such provision shall be struck and the remaining provisions shall be enforced. In our sole discretion, we may assign this Terms of Use Agreement. Headings are for reference purposes only and do not limit the scope or extent of such section. Our failure to act with respect to a breach by you or others does not waive our right to act with respect to subsequent or similar breaches. We do not guarantee we will take action against all breaches of this Terms of Use Agreement.
17. Changes to the User Agreement
This Terms of Use Agreement is effective on February 15, 2017. Lassonde Pappas may make changes to the Terms of Use Agreement from time to time. When these changes are made, we will make a new copy of the Terms of Use Agreement and make it available to all users by posting it on our website and all amended terms shall automatically be effective 60 days after they are initially posted. You understand and agree that if you use our website after such date, Lassonde Pappas will treat your use as acceptance of the updated Terms of Use Agreement.

Privacy Policy

 The privacy of your personal information is of the utmost importance to Lassonde Pappas and Company, Inc. (“Lassonde Pappas”, “we”, “us” or “our”, as appropriate). This Privacy Policy covers the information that we collect about you or that you provide to us online through our website located at http://www.lassondepappas.com or any website owned and controlled by us (the “Lassonde Network”). By visiting or using our website, you agree to be bound by the terms and conditions of this Privacy Policy.

    1. 1. Collection and Use of Personal Information

Information you provide: We may collect your personal information such as your name, contact information and e-mail address when you willingly subscribe to a service such as our newsletter service, when you request access or download certain media content or make an inquiry through our website. You will know when we collect this information because you will be asked to provide us with your information. We will only use this information, as the case may be, to provide you with the requested services or information, to contact you in order to answer your question, for internal quality assurance purposes or to manage the quality of our media information provided through our website. We may also use your email address in order to inform you of our products or promotions which may be of interest to you, but these marketing communications will be done in compliance with anti-spam laws, and you may, at all times, request that we remove your email address from our marketing list.

Certain websites within the Lassonde Network may include a section entitled “Careers”. We may therefore collect your resume and other related information upon you submitting your resume and other professional experience information through our website in which case, we will only use this information in order to evaluate your application, or to contact you to confirm that your application has been received or to discuss potential employment opportunities at Lassonde Pappas.

Certain websites within the Lassonde Network may include a Web-based Message Board. We wish to inform you that the risks associated with the supplying of personal information in a blog, chat room or on a Web-based Message Board are not covered by our Privacy Policy; thus, you must be extremely careful if you choose to supply personal information through these means. You are submitting this information at your own risk. Indeed, this information may be collected and used by third parties without your prior consent. In other words, if you choose to provide personal information online and this information is available to the public, you may, eventually, receive unsolicited e-mail from third parties. We decline all responsibility in this regard. We urge you to remain cautious and vigilant, at all times, on the Internet.

Technical information: When you visit our website, we may collect, using electronic means (such as cookies), technical information. This information may include the IP address of your computer, which browser you used to view our website and your operating system. This technical data is used to provide you with a personalized experience on the websites within the Lassonde Network, and is aggregated and used to measure and improve the effectiveness of our website.

  1. 2. Sharing of Personal Information

Unless we have your express consent, we will not sell, rent, share or trade your personal information to any third party, except within the Lassonde Network or to internal service providers that we use to facilitate or outsource one or more aspects of the operation of our website. These internal service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any purpose other than to facilitate the specific outsourced related operation, unless you have explicitly agreed or given your prior permission to them for additional uses.

In the preceding 12 months, we have not sold or disclosed to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

From time to time, we may be required to provide personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of others and ourselves.

  1. 3. Links to Third Party Websites

Our website contains links to third-party websites; these are provided solely for your convenience. Clicking on these links will take you outside of the Lassonde Network. Please be advised that we have no control over these third-party sites and, while our website may feature such links, we will not, at any time, accept liability for these sites. Consequently, personal information that you provide to a website outside of the Lassonde Network is subject to the privacy policies of the given third-party site. In the event of abuse by such websites, we cannot, at any time, be held responsible. Therefore, we strongly urge you to carefully read the privacy policies of all third-party websites you choose to enter.

  1. 4. Children

We take special precautions to comply with applicable laws and self-regulatory programs regarding children’s advertising and privacy. Although most aspects of our website are intended for a general audience and not children, it is possible that certain websites or subsections of websites within the Lassonde Network may appeal to children. For instance, in the event that special games or contests targeting children are made available on our website, additional terms and conditions specific for these activities will be displayed and we will ensure that any collection and use of personal or contact information of children is done in compliance with laws, with verified parental consent. We do not intend to collect personal information from children absent verified parental consent or as otherwise allowed by law. If you think we have, please let us know.

  1. 5. Anti-Spam

Lassonde Pappas is committed to providing transparency to outside parties (which we may electronically communicate) with respect to our practices in complying with United States federal and state anti-spam legislation and associated rules and regulations, including the CAN-SPAM Act (“Anti-Spam Laws”). The types of commercial electronic messages that Lassonde Pappas may send from time to time could include messages pertaining to our products and services including our newsletter to recipients that have agreed to receive them, messages sent to our current or potential customers and messages sent to our current or potential service providers or business partners by our various business units.

If you have received a commercial electronic message from Lassonde Pappas it is because either you have previously provided your express consent, we have your implied consent under the Anti-Spam Laws, or because the type of message sent is exempt under Anti-Spam Laws.  If you have received a CEM, and you believe that you should not have, please contact us immediately at privacy@lassonde.com in order to unsubscribe and we will remove your electronic address from our list within 10 business days.

  1. 6. Sale of Business

In the event that we intend to sell or transfer ownership or control of any or all of our business, operations or services to a third party, we reserve the right to disclose your personal information to a potential buyer both before and after the purchase. However, in the event the sale goes through, we will require that the receiving party agree that they will be similarly bound by the provisions of this Privacy Policy and that they will only use and disclose your personal information as we are similarly entitled under this Privacy Policy. In the event the sale does not go through, we will require the potential purchaser to not use or disclose your personal information in any manner whatsoever and to completely erase the same.

  1. 7. Cross-border Data Transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which Lassonde Pappas operates (including Canada) to enable the use of the information in accordance with this Privacy Policy. In such situation, your personal information may be subject to these foreign jurisdictions’ laws. You agree to such cross-border transfers of your personal information.

  1. 8. Security of Personal Information

We will use reasonable security measures to protect your personal information against unauthorized access. Please be careful whenever sending personal information to Lassonde Pappas via e-mail. E-mail is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and we encourage the use of e-mail encryption to communicate with us.

  1. 9. Governing Law and Jurisdiction

The laws of the State of Delaware shall apply to the interpretation of this Privacy Policy notwithstanding any conflict of law provisions. All proceedings relating to this website or to this Privacy Policy shall be brought before the courts of the State of Delaware.

  1. 10. Change in Privacy Policy

If there is any material change in our Privacy Policy, the revised statement will be posted on this website. Regardless of any changes we make to our Privacy Policy, we will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you later give your express consent for us to do otherwise.

  1. 11. Your Rights and How to Exercise Them; Our Contact Information

You have the right to request information about any of the following:

  • The categories of personal information we have collected about you;
  • The specific pieces of information we have collected;
  • The categories of sources from which the information is collected;
  • Our business or commercial purpose for collecting the information; and
  • The categories of third parties with whom we share the information, if any

Subject to certain exceptions (listed below) and a verifiable request, you also have the right to request:

  • That we delete your personal information from our records; and
  • That we direct any service providers to delete your personal information for their records.

Please note that we may not delete your personal information if it is necessary to:

  • Complete a transaction for which the personal information was collected, provide a good or service requested by you, otherwise perform a contract between you and us, or if the collection of the information was reasonably anticipated within the context of our ongoing business relationship with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

In addition, you have the right not to be treated differently by us because you exercised any of these rights, and we will never do so.

How to Exercise Your Rights:

If you would like to exercise any of your rights under this Privacy Policy, or if you would like this notice in another format, please:

Once you contact us, you will need to provide us with:

  • Enough information to identify you;
  • Proof of your identity and address; and
  • A description of what right(s) you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

This Privacy Policy was last updated on January 1, 2020.

“Cookies” are little bits of information that are sent to your computer when you visit a website. They are saved, either temporarily or permanently, on your hard drive, leaving a trace of your passage. The information can include information such as the date and time of your last visit, a given answer to an online question, personal information, etc. Cookies can also enhance your web experience by recording your navigation preferences for a given website.

Cookie files stored on your hard drive are harmless and they may be read and deleted at any time. Thus, you always have complete control. Cookies provide important data for our marketing department. Indeed, this information enables us to know the total number of visitors for each of our websites within the Lassonde Network and the length of each visit. Upon using a website within the Lassonde Network, a cookie file is created and stored on your computer, enabling us to “recognize” you every time you visit one of our websites within the Lassonde Network.

Most Internet browsers will accept cookies by default. If you so choose, you may, at any time, change your parameters to disallow the use of cookies. However, in doing so, you will be unable to access the full features of our website.

Statement Regarding California Transparency in Supply Chains Act

 

Lassonde Pappas and Company, Inc. (“Lassonde Pappas”, “we”, “us” or “our”, as appropriate) supports the goals of the California Transparency in Supply Chain Act, which requires companies to disclose the efforts they have made to ensure that their supply chains are free from slavery and human trafficking. To that end, Lassonde Pappas seeks to ensure that quality and safety standards are maintained throughout our supply chain and that workers are treated fairly and in accordance with all applicable laws. We have undertaken the following efforts to help prevent slavery and human trafficking in our supply chain:

  • We periodically review our supply chain and supplier base to determine the level of risk associated with each supplier with respect to slavery and human trafficking based on our knowledge of their industries and their country of origin, and if we believe it is appropriate to do so, we will switch our source of supply to a supplier with a lower level of risk. Employees of Lassonde Pappas and representatives of our company conduct site visits of suppliers located outside of the United States on a periodic basis and provide annual certifications that based on their knowledge and information the supplier is not engaging in slavery or human trafficking. We have not yet begun conducting independent, unannounced audits of third party suppliers, nor have we used a third party to verify the risks in our supply chain.
  • In order to meet the Act’s directive relating to supplier certification, each of our suppliers certifies to us that they adhere to the standards of the Ethical Trading Initiative (“ETI”), which can be found at www.ethicaltrade.org.
  • If we have reason to believe that a supplier is not in compliance with the ETI standards as they relate to the California Transparency in Supply Chain Act, we will take appropriate steps, including the elimination of the supplier from Lassonde Pappas’s supplier base or, if the violation is less severe, the opportunity to remedy the non-compliance through the development and execution of a corrective action plan.
  • We have ensured that key employees from our Procurement/Supply Chain organization are trained to identify and respond to supply chain risk issues such as forced or child labor as part of our procurement process. Key employees were trained by the effective date of the law (January 1, 2012) and we will assess the need for additional or refresher training as appropriate.

Lassonde Pappas believes that the activities listed above will promote the goals of the Act and help prevent slavery and human trafficking in our supply chain.