CA Disclosure

Pinnacle Agriculture Holdings, LLC and its subsidiaries, including Pinnacle Agriculture Distribution, Inc., (“Pinnacle”) are committed to conducting business ethically and with integrity, in treating all people with dignity and respect and in complying with applicable laws and regulations. Pinnacle™ does not tolerate illegal child labor, slave labor, or human trafficking. These principles and commitments are embodied in our Code of Business Conduct, corporate policies and our Code of Business Conduct for Suppliers.

We comply with employment laws applicable to our business and expect those with whom we do business to do the same. The California Transparency in Supply Chains Act of 2010 requires Pinnacle to disclose the following:

Verification. Pinnacle routinely assesses risk related to its supply chain. This assessment is based primarily upon supplier quality performance, the type of transaction, the specific commodity purchased, the geographic location of the source and other relevant business and legal criteria. Pinnacle follows the trade laws of the United States, including the restrictions on export or doing business with certain people, companies or countries. Pinnacle’s Code of Business Conduct for Suppliers specifically identifies the expectation that our suppliers must conduct business in a way that is not complicit in any human rights abuses, including child labor, slave labor and human trafficking and reserves Pinnacle’s right to investigate any discovered instances of non-compliance with our Code of Business Conduct for Suppliers. Other than the foregoing, Pinnacle has no formal process for verification of supply chains to evaluate and address risks of human trafficking and slavery.

Auditing. Pinnacle has audit rights in many of its supply contracts, which permit Pinnacle to audit a supplier’s compliance with the terms of the contract. While Pinnacle has certain contractual rights to audit its suppliers, and has conducted routine audits or assessments of supplier performance, those assessment methodologies do not currently include specific assessments of human trafficking and slavery. Pinnacle has reserved the right to investigate instances of non-compliance with our Code of Business Conduct for Suppliers, including instances of non-compliance with laws governing human trafficking and slavery.

Certification. Pinnacle’s contracts with suppliers require suppliers to comply with all laws. Our suppliers are also required to adhere to our Code of Business Conduct for Suppliers, which states our expectations of compliance with laws and ethical business conduct, including those laws and principles prohibiting involvement in slave labor and human trafficking. Other than these contractual obligations with suppliers and Pinnacle’s reservation of right to investigate, Pinnacle does not have a formal supplier certification process.

Internal Accountability. Under Pinnacle’s Code of Business Conduct, Pinnacle employees are required to follow all applicable laws and all of Pinnacle’s policies. Employees who violate laws for Pinnacle’s policies are subject to disciplinary action including discharge. Pinnacle’s suppliers are subject to the terms of all contracts with Pinnacle, including obligations to comply with the Code of Business Conduct for Suppliers. Pinnacle reserves its contractual rights to terminate relationships with suppliers who fail to comply with law and/or whose contractual noncompliance is not addressed in a timely manner.

Training and Awareness. Pinnacle regularly trains its employees in the standards of ethical behavior, policies, procedures and legal requirements that establish the manner in which we conduct business. We do not require our employees to engage in training that specifically pertains to slave labor and human trafficking. If an employee responsible for procuring materials for our operations were to suspect a supplier of being involved in slavery or human trafficking, the employee would have a responsibility under Pinnacle’s Code of Business Conduct not to ignore such suspicion, but to take action appropriate to the employee’s position at Pinnacle.

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