The California Transparency in Supply Chains Act of 2010 (SB 657) went into effect on January 1, 2012. This law requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. A. Schulman is proud of its record of uncompromising integrity and the measures it takes to uphold the highest standards of conduct among its associates, business partners and suppliers.

A. Schulman's efforts to eradicate slavery and human trafficking in its supply chain include the following:

• Written Policies and Procedures: A. Schulman maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain. Among other provisions, the A. Schulman Global Code of Conduct requires all A. Schulman suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking, as those terms are used in the California Transparency in Supply Chains Act of 2010, California Civil Code, section 1714.43.”
• Supplier Certifications: A. Schulman suppliers are contractually obligated to comply with our Global Code of Conduct.
• Random Audits: A. Schulman has the right to audit any or all suppliers for compliance with the A. Schulman Global Code of Conduct and compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in the California Transparency in Supply Chains Act of 2010.
• Accountability Standards: A. Schulman has a zero tolerance policy for violations of the laws banning forced labor, slavery and human trafficking. A. Schulman's disciplinary policy permits a range of measures, up to and including termination, for A. Schulman suppliers and associates who violate A. Schulman's policies, including its policy banning forced labor, slavery and human trafficking.
• Associate Training: A. Schulman conducts training for associates whose job functions include procurement that emphasizes the importance of ensuring that A. Schulman's suppliers abide by the A. Schulman Global Code of Conduct, including its prohibitions on slavery and human trafficking. It is essential to A. Schulman that all persons involved in the production of our products, whether A. Schulman associate or not, are treated with dignity and respect. A. Schulman will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain.

Dated: June 2012