California Transparency in Supply Chain Act Disclosure

The California Transparency in Supply Chain Act was enacted in 2010 (the “Act”). The Act requires companies meeting certain criteria when doing business in California to publish information on their websites disclosing certain efforts taken to ensure slavery and human trafficking are not part of their supply chains.

Specifically, the Act, as codified in the California Civil Code and Revenue and Taxation Code §19547.5, mandates that qualifying companies disclose whether they have formal policies or practices in place to eradicate slavery and human trafficking, by confirming to what extent, if any, they: (i) verify product supply chains; (ii) audit suppliers; (iii) require certifications from suppliers as to whether materials incorporated into their products comply with applicable laws regarding slavery and human trafficking; (iv) maintain internal accountability standards for employees or contractors; and (v) provide training on mitigating supply chain risks.

Ajax TOCCO Magnethermic and its subsidiaries (“ATM”) do not currently have formal policies or procedures in effect that address the five requirements set out in the Act.

ATM is committed to complying with all applicable laws wherever ATM conducts business.  ATM conducts its business with integrity in all locations where ATM operates.  As set out in the ATM Code of Business Conduct and Ethics, employees are expected to comply with all applicable laws, rules, and regulations. Additionally, ATM employees participate in Code of Conduct training sessions. ATM also expects its suppliers to comply with applicable laws, rules, and regulations.

In 2015, ATM plans to commence evaluating methods for ensuring against human trafficking in its supply chain.