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Statement of Compliance: SB 657

Boiron Inc. (Boiron USA) Statement of Compliance
California Transparency in Supply Chains Act.

Boiron, Inc. complies with the California Transparency in Supply Chains Act of 2010 (SB 657) which became effective on January 1, 2012. This law requires large retailers and manufacturers doing business in the state of California and have gross worldwide sales exceeding $100 million to be transparent about the effort they have undertaken to eradicate slavery and human trafficking in their supply chains.

Boiron, Inc.  supports the United Nations Universal Declaration of Human Rights.  Boiron, Inc.  undertakes to implement universally recognized principles in the areas of human rights, labor standards, environmental protection and anti-corruption throughout the organization when developing business processes and strategies.

Boiron, Inc. is in the process of memorializing a comprehensive Supplier Code of Conduct in efforts to combine all of our fundamental sustainability standards and requirements.  These standards include: areas of ethics, employee relations, management systems, health, safety, environment quality and regulatory compliance.

Suppliers are expected to protect the human rights of their employees and to treat them with dignity and respect.
Boiron, Inc. expects our suppliers to accept these sustainability principles including child labor avoidance and no utilization of forced, bonded or indentured labor or involuntary prison labor.

Using supplier self-assessment and other risk indices Boiron, Inc decides which suppliers to be audited for compliance with Boiron, Inc’s requirements.
Boiron executives along with an independent external auditors (not all audits include independent auditors) carry out announced audits of our direct suppliers to confirm the supplier’s compliance with Boiron’s expectations.

Assessment is made after audit to determine whether we need to define further development measures and goals in collaboration with suppliers.  Unacceptable progress during the post audit optimization process can result in termination of or failure to award contracts.

As part of the Company’s efforts to continuously improve and enhance its supply chain management systems, Boiron is developing training for those employees and management who have direct responsibility for supply chain management. The training program will familiarize our procurement staff with risks within the supply chain relating to compliance with Boiron’s  expectations. The training will be mandatory and will cover the principles of sustainability mentioned above.

All contracts over a predetermined threshold must comply with Boiron’s internal standard for financial independence, capability and compliance with sustainability principles.  Boiron employees are barred from accepting gifts or other inducements in return for acceptance of contracts.