California Transparency in
Supply Chains Act of 2010

This describes Gatekeeper Systems (the “Company”) efforts to reduce the risk for modern slavery and human trafficking in our Company’s direct supply chain for tangible goods offered for sale.

The Company is working to deploy a “Supplier Manual” in 2021 which describes the business practices and employment standards applicable to the Company’s worldwide direct suppliers. Direct suppliers will receive copies of the Supplier Manual annually will be expected to post these policies on site at their various locations.

The Company uses significant efforts to verify the absence of forced labor and child labor in its supply chain, including the following:

Direct Supply Chain Verifications

The Company evaluates actual and potential suppliers according to a risk-based strategy. New supplier screens are conducted by Company personnel.

Direct Supply Chain Audits

The Company has a multi-faceted program to audit suppliers’ compliance with its policies. Supplier compliance is monitored by supplier self-assessments, Company questionnaire requirements, Company personnel visits and third-party audits. Many suppliers are required to report their compliance (via detailed questionnaire-based reports) either annually or bi-annually, depending on their risk profile. Various types of audits are conducted, including onsite visits by Company personnel. Periodic unannounced third-party on-site audits for suppliers may be conducted on each of the categories listed in the Supplier audit.

Internal Accountability

If concerns are identified over the course of questionnaire and/or audit processes, suppliers must produce corrective action plans describing how they will resolve issues uncovered in audits. The Company will terminate a supplier relationship if serious non-compliance is discovered (such as child or forced labor).

Direct Supply Chain Certifications

The Company requires the supplier to comply with all applicable laws and regulations, including local laws regarding forced and child labor. In addition, the Company requires direct suppliers to certify that materials incorporated into the Company’s products comply with the laws of the countries where the suppliers are doing business via its questionnaires and audit/corrective action programs.

Employee and Management Training

The Company has an extensive team member compliance training program and team members who are responsible for supply chain management have been trained regarding these supply chain issues. All worldwide Company team members must comply with the Company’s Code of Business Conduct and Ethics (v2021), which addresses the principle that child, prison, or forced labor are not permitted at any Company or Company supplier operation. The Company periodically trains team members on these standards, including training for all new team members and refresher training of all Company team members and management, including those who have direct responsibility for supply chain management.

Gatekeeper Systems takes great pride in the integrity of its operations, including those in its direct supply chain. We strive to achieve best practices in everything that we do. Accordingly, we may periodically update this Disclosure to reflect current practices.

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