California Transparency Act

Nashville Wire Products (“NWP”) and our affiliates conduct our business in accordance with high ethical standards and expect our business partners to share in this philosophy. NWP utilizes these standards in the selection of its business partners, expecting full compliance from all of NWP business partners, including all manufacturers, contractors, subcontractors and suppliers. It is imperative that NWP customers have confidence that our products are produced, transported, and sold in full compliance with regulatory requirements regarding workers’ rights, and that NWP business partners provide a safe and healthy work environment for their workers. NWP business partners must adhere to this Business Partner Code of Conduct. For purposes of this Code, the phrase “applicable law” means all federal, state and local U.S. laws as well as all applicable laws of other countries in which NWP business partners operate. NWP audits its business partners for compliance with this Code under appropriate circumstances.

I. WORK ENVIRONMENT

NWP will only work with business partners who provide a safe and healthy workplace and working and living conditions that comply with applicable law. NWP expects all business partners to promote employee health and safety through internal training and awareness programs.

II. LABOR POLICY

Business partners will not use forced or compulsory labor, perceived or otherwise, in the design, manufacture or transportation of products for our stores. Labor, including overtime, must be voluntary at all times.

III. EMPLOYEE DISCIPLINE

Business partners will not utilize physical or mental punishment, including psychological coercion, perceived or otherwise, against their employees. Employees of business partners must be treated with dignity and respect at all times.

IV. EQUAL EMPLOYMENT OPPORTUNITIES

NWP has the highest respect for cultural differences. However, NWP believes workers should be employed based upon their abilities, rather than their race, gender, or personal characteristics or beliefs. Discriminatory behavior in the workplace will not be tolerated.

V. WORKERS’ RIGHTS

NWP expects that its business partners will abide by all applicable laws respecting the rights of workers. Business partners are encouraged to develop internal programs, policies and procedures that clearly define their business practices and provide employees with a viable means of managing conflict and resolving disputes.

VI. WORKING HOURS

NWP business partners will not require their employees to work a number of hours during a week that exceed what is allowed under applicable law. Business partners should maintain a workweek consistent with normal hours of operation for their industry, with compensated overtime, in compliance with applicable law.

VII. WAGES & BENEFITS

NWP business partners must provide wages and benefits in compliance with applicable law, and be committed to the betterment of wage and benefit levels that address the basic needs of workers and their families.

VIII. CHILD LABOR

Business partners will not utilize child labor. Child labor is defined as either being below the local minimum working age, or the age of 14, whichever is greater.

IX. COUNTRY OF ORIGIN

Business partners will not use deceptive trade practices to deliberately misrepresent country of origin in order to evade quota or other import restrictions.

X. ENVIRONMENTAL

Business partners will work in full compliance with all applicable environmental regulations. Failure by any business partner to comply with the requirements detailed above may lead to the immediate cancellation by NWP of all outstanding purchase orders, contracts or other business with that business partner. Furthermore, NWP reserves the right to reject any service or product and return any merchandise not produced or supplied in compliance with this Code and charge the business partner for all costs, expenses or losses related thereto.