The California Transparency in Supply Chains Act of 2010

McCormick Distilling Co., Inc. is a distilled spirits company located in the United States, doing business in the domestic and certain foreign markets. We comply with federal, state, and foreign laws regarding labor practices wherever we operate.

The California Transparency in Supply Chains Act of 2010 (SB 657) (“Act”) seeks the elimination of slavery and human trafficking from product supply chains and requires that large companies who do business in California disclose their efforts toward the elimination of slavery and human trafficking. The information below relates to our efforts to comply with the Act.

1.) The vast majority of our suppliers are located in North America, principally in the United States, and in the European Union. To the best of our knowledge and belief, no supplier to our company, whether located within or without the United States, has ever been accused of engaging in forced labor or human trafficking.

2.) We reserve the right to audit our suppliers operations to ensure compliance with the Act. Currently, audits are not regularly performed by the company or an independent third party.

3.) Our purchase orders and supplier contracts will now contain an express representation that each supplier will comply fully with all applicable laws prohibiting human trafficking and slavery and that any violation of such laws are cause for immediate termination of our contracts and orders. We will terminate our contract with any supplier found to be in violation with our policy on human trafficking and slavery.

4.) To further our efforts to eradicate human trafficking and slavery from our supply chain, we have now asked suppliers to return a signed statement to us acknowledging that they support the elimination of forced labor and human trafficking.

5.) Our Employee Code of Conduct requires that company personnel try to ensure we work only with reputable suppliers. Employees annually affirm their compliance with our Employee Code of Conduct, but we have no formal training related to the issue.