California Transparency in Supply Chains Act of 2010

Last Revision Date: 9/18/2020

DS Services of America, Inc. dba Primo Water North America (“Primo”, the “Company”, “We”, “Us”) fully supports the goals of the California Transparency in Supply Chains Act of 2010. We are committed to the highest level of ethics and integrity in all our business operations. This is reflected in how we treat each other, our customers, and our suppliers. Primo expects its associates and suppliers to be in full compliance with all laws and regulations, and to conduct themselves ethically with regard to human rights and labor practices in all business dealings with and for us. At Primo, compliance with the law means observing both the letter and spirit of the law and conducting our business affairs so that we maintain the highest respect in our industry.

Our Code of Business Conduct and Ethics is the basis for our culture, and we similarly expect our suppliers to abide by ethical labor practices and operate with equally high values and standards of conduct.  Primo opposes human trafficking in all its forms and is committed to the goals of the California Transparency in Supply Chains Act of 2010 through the following efforts:

Procurement/Verification

Our Code of Business Conduct and Ethics provides practical direction on how to live our values at work. It also gives guidance on following applicable laws and regulations and ethical standards expected for our business.  This extends to the exercise of due diligence in selecting and retaining any third party (e.g., consultants, representatives, suppliers, independent contractors) to supply, represent, or perform work for Primo. Our internal supply chain evaluation protocols include the assessment of risks such as human rights and labor violations. In the event concerns arise, we will investigate and take appropriate action to mitigate the risk and verify that the supplier complies with all applicable laws and with our ethics policies.  Primo does not use third-party monitors or labor brokers.

Reporting/Internal Accountability

At Primo, all associates are encouraged to report any suspected wrongdoing either to a supervisor or through our third-party ethics reporting system.  This system allows for associates to submit confidential and, if desired, anonymous reports either online or via a toll-free phone number. Our Company maintains a strict policy of non-retaliation for reports made in good faith. All reports are thoroughly investigated. Procurement associates who have knowledge of a supplier engaging in slavery or human trafficking and who fail to report it may be subject to discipline, up to and including termination.

Supplier Agreements/Certifications

Primo strives to include representations in all its purchasing agreements and purchase order terms and conditions with direct suppliers, thus verifying that they comply with all applicable laws and regulations, including those protecting human rights. Although Primo does not currently require all of our suppliers to specifically certify that materials incorporated into their products comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business, Primo is committed to reviewing and revising its supplier contracts and arrangements on a go-forward basis to help verify that our suppliers' products (including any material incorporated in those products) fully comply with all laws, including human rights laws, and that our supply chain is free from human trafficking or slavery.

Supplier Audits

Primo’s standard supplier contract provides the Company with the right to audit our third-party suppliers. If Primo becomes aware of any possible risk that a supplier is not acting ethically with regards to human rights, we will exercise this right and demand corrective actions for any noted violations, up to and including termination of the agreement. Because Primo does not believe this risk in its supply chain is significant, we have not audited our suppliers for compliance. Primo reserves the right to verify that all our suppliers comply with all applicable agreements, laws, and regulations, including the protection of human rights and the enforcement of ethical labor practices.

Associate Training

All associates receive a copy of the Company’s Code of Business Conduct and Ethics and acknowledge that they will comply with our policies. Primo also provides supplemental training on Company policies and compliance to appropriate associates as befitting their respective roles within the organization. Procurement professionals receive additional training on slavery and human trafficking including how to identify and mitigate supply chain risks.