California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 (”CTSCA”) requires companies above a certain size that manufacture or sell products in California to report on their websites the activities they engage in to ensure that their supply chains are free from slavery and human trafficking. Slavery and human trafficking are both illegal and unethical, and Lightopia works to combats these issues as part of its overall commitment to complying with all applicable laws and regulations and operating in an ethical and socially responsible manner. Lightopia expects its partners to conduct their businesses not only in a lawful manner, but also in compliance with the same high standards of integrity and ethics. At this time, Lightopia does not have any affirmative verification, auditing, certification, internal accountability, or training standards or procedures relating to the eradication of slavery and human trafficking. However, if we come to learn that one of our suppliers has engaged in slavery, human trafficking, or other forced labor or human rights abuses, we reserve the right to terminate that relationship immediately.

1. Lightopia expects its partners to refrain from the direct or indirect use of slavery, forced labor or any forms of human trafficking. Lightopia uses formal and informal means to monitor its supply chain to evaluate the risks of noncompliance involving slavery and human trafficking issues. This monitoring effort is conducted by both Lightopia and third parties. To that end, Lightopia will not knowingly do business with any supplier that supports, condones, or otherwise has issues with slavery, human trafficking, or forced labor.

2. Lightopia informally assesses all potential suppliers during onboarding to detect any issues concerning slavery and human trafficking, but does not currently conduct any formal audits. If a supplier is determined to have violated applicable laws or has a higher level of risk in this regard, Lightopia will take all appropriate action, which may include ending the partnership.

3. Lightopia does not currently require its manufacturing or delivery partners to make any certifications regarding human trafficking or slavery.

4. Lightopia does not currently have any specific standards or procedures in place that pertain to slavery and human trafficking.

5. Lightopia does not currently conduct any specific management or employee training on the issues of slavery and human trafficking.