California Transparency in Supply Chains Act Statement

Halfday is committed to the global eradication of all forms of modern slavery, in particular forced labor, child labor, bonded and indentured labor, and human trafficking.

In alignment with Halfday’s values, and to address the specific requirements of the California Transparency in Supply Chains Act of 2010 (S.B. 657), Halfday makes the following disclosures:

1. Verification
Halfday is in the process of implementing purchase order terms that specifically require that all of its sellers confirm they do not have any form of child, forced, or trafficked labor in their supply chains. Such terms will further align with U.S forced labor laws, as amended by the Uyghur Forced Labor Prevention Act of 2021. Although Halfday has not yet needed to undertake verification of its supply chains to evaluate and address risks of human trafficking and slavery, we will do so when credible evidence or allegations of such human rights abuses are brought to our attention.

2. Audits
Halfday is in the process of requiring that all its suppliers and sellers with which Halfday enters into new contractual relationships maintain systems of internal controls to document and ensure compliance with all applicable laws related to child, forced, or trafficked labor. Halfday does not currently engage third-party monitors to evaluate supplier compliance, but will consider engaging an independent human rights expert to evaluate specific compliance issues when such expertise is needed to address credible allegations, and as a complement to our own existing due diligence efforts.

3. Certification
Halfday will source its products from suppliers and enter into purchase order agreements with sellers who certify that all materials incorporated into their products comply with all applicable laws regarding slavery and human trafficking of the country or countries to which they have a material commercial linkage. Halfday is in the process of adding purchase order language for new agreements requiring suppliers to confirm that they do not produce any goods, or portions of such goods, through any form of child, forced, or trafficked labor, and that they are in compliance with U.S. forced labor laws, as amended by the Uyghur Forced Labor Prevention Act. Noncompliance with Halfday terms regarding forced labor will result in cancellation of the applicable order and may be grounds for terminating all future business relationships.

4. Internal
Accountability. Halfday maintains internal accountability standards and procedures for employees or contractors who fail to meet Halfday standards regarding slavery and trafficking and applicable laws. All Halfday employees are provided with our Human Rights Policy and are required to act in compliance with the policy at all times. Actions taken by employees contrary to the Human Rights Policy may result in disciplinary action, including termination of employment.

5. Training
Halfday does not currently provide training regarding forced labor and modern slavery to employees and management. All employees, however, are provided with the Human Rights Policy and are also provided an orientation regarding its key provisions and their obligations to comply with the Policy.