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Supply Chain Transparency

The Wine Group and its affiliates respect the human rights of our employees and those of our suppliers, and are committed to supporting fair labor standards. As a responsible corporate citizen, we seek to do our part to help prevent slavery and human trafficking in our supply chain and prefer that our supply chain is staffed by well-treated, voluntary and fairly compensated workers who enjoy the protection of all applicable laws in their respective countries.

As of January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires certain companies doing business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their direct supply chain. As a policy, we do not knowingly employ slaves or trafficked persons, or knowingly tolerate forced labor of any kind by our suppliers. We source the majority of our supplies from countries that have strict labor and employment laws that prohibit slavery and human trafficking. Below, we describe some of the actions we have taken with respect to our business relationships with our vendors to endeavor to promote decent and humane working conditions within our direct supply chains.

Supplier Certification

To help ensure that our major suppliers of goods and services respect and uphold our company standards and the law, we include a clause in our standard purchase documents requiring the supplier to comply with all applicable local, state, and federal laws.

At our request, the majority of our highest dollar value direct suppliers has certified that the materials they sell to us to be incorporated into our products are produced in compliance with the laws regarding slavery and human trafficking of the countries in which the suppliers do business. If we believe that a supplier is not in compliance with our standards with respect to slavery and human trafficking, we will provide such supplier with the opportunity to remedy any potential non-compliance through the implementation of a corrective action plan. Should the supplier continue to fail to meet our standards, we will consider replacing the supplier with a different vendor who does comply with applicable slavery and human trafficking laws.

Supplier Verification and Audit

While we conduct on-site visits to suppliers from time to time to evaluate a variety of factors, we have not yet begun to engage in the verification of product supply chains to evaluate and address risks of human trafficking and slavery, or to conduct third party audits of suppliers to evaluate supplier compliance with human trafficking and slavery laws.

Internal Accountability and Training

Our employees and contractors are expected to comply with our company policies and all applicable local, state, and federal laws, regulations, codes and ordinances, including those regarding fair labor practices. At this time, we do not maintain internal accountability standards or procedures for employees or contractors failing to meet company standards regarding slavery and trafficking, or provide company employees and management who have direct responsibility for supply chain management with training specifically on human trafficking and slavery.

On-going Improvement

It is important to TWG that all persons involved in our product supply chain, whether our employees or not, are treated with dignity and respect. We will continue to evaluate our standards, policies and procedures as needed to help ensure that we have reasonable and appropriate safeguards against slavery or human trafficking involvement in our direct supply chains.

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