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Response to California Transparency in Supply Chains Act of 2010

Valspar has a zero-tolerance policy for the use of forced or child labor in the production of its goods. As evidenced in our Code of Ethics and Business Conduct Policy Valspar strives to treat its employees fairly, respectfully and in compliance with all applicable workplace laws, including international prohibitions on slavery, forced labor, child labor and human trafficking. We expect the same of our direct suppliers, and our Standard Purchase Terms and Conditions requires suppliers to warrant that they will comply with laws prohibiting slavery and human trafficking in any country in which they are doing business. Any violation of these terms is considered grounds for immediate termination of the business relationship. Valspar additionally reserves the right to audit suppliers, directly or through a third-party, to confirm that the materials being supplied are generated without reliance on forced labor or human trafficking.

It is Valspar's policy not to do business with suppliers or others that do not comply with applicable labor laws, including prohibitions on slavery and forced labor. Valspar's Code of Ethics and Business Conduct Policy is unequivocal: "Valspar will not purchase or use goods or services that have been manufactured or provided in violation of applicable labor laws." Valspar trains employees with direct responsibility for supply chain management on compliance with the Code of Ethics and Business Conduct Policy and requires them to certify on an annual basis that they are in compliance with its terms.