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Reyes Coca-Cola Bottling, L.L.C., (“RCCB”) is committed to conducting business in an ethical manner in compliance with all applicable Federal and State anti-slavery, human trafficking and labor laws. This statement is made pursuant to the California Transparency in Supply Chain Act and sets out steps RCCB and the US Coca-Cola bottling system have taken to ensure that slavery, forced labor and human trafficking are not taking place in our supply chain. At RCCB, we hold ourselves and our vendors accountable to high ethical standards. RCCB works diligently to ensure that our products are produced ethically by our suppliers.


In the United States, the Coca-Cola Bottlers’ Sales and Services Company LLC (“CCBSS”) coordinates and chooses the direct materials suppliers for the Coca-Cola Bottling System and assigns those suppliers to individual bottlers such as RCCB to optimize service and value for the US Coca-Cola bottling system. CCBSS can only engage suppliers who are authorized and approved by The Coca-Cola Company (“TCCC”). These suppliers must adhere to TCCC’s Supplier Guiding Principles which prohibit the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, slave labor and any form of human trafficking. The Supplier Guiding Principles are embedded into contractual agreements and purchase orders between TCCC and direct authorized suppliers. Further, included in each CCBSS contract is a requirement that the supplier adhere to the Supplier Guiding Principles. Suppliers are required to develop and implement appropriate internal business processes to ensure compliance with the Supplier Guiding Principles.


Specifically, under the Supplier Guiding Principles, each direct supplier to the US CocaCola bottling system is required to (i) comply with all applicable child labor laws; (ii) not use forced, bonded, prison, military or compulsory labor; (iii) comply with all applicable laws on abuse of employees and not physically abuse employees; (iv) comply with all applicable laws on freedom of association and collective bargaining; (v) comply with all applicable non-discrimination and equal opportunity laws; (vi) comply with all applicable wage and benefits laws; (vii) comply with all applicable work hours and overtime laws; (viii) comply with all applicable health and safety laws; (ix) comply with all applicable environmental laws; and (x) demonstrate compliance with the Supplier Guiding Principles at the request and to the reasonable satisfaction of CCBSS and TCCC.


TCCC routinely utilizes independent third parties to assess a supplier's compliance with the Supplier Guiding Principles. These assessments generally include confidential interviews with employees and on- sitecontractworkers. IfasupplieratanytimefailstoupholdanyaspectoftheSupplierGuidingPrinciples, the supplier is expected to promptly implement corrective actions. TCCC works with suppliers to implement corrective actions and demonstrate compliance through a follow-up assessment. Depending on the type of finding, corrective actions are expected to occur to remediate issues immediately for critical findings or within 30-90 days for those findings that require additional implementation time. Validation of remediation occurs through in-person or remote follow-ups. A remote follow-up would suffice when documents can be provided to show corrective action while in-person follow-ups are scheduled if interviews or visual inspection are needed. CCBSS reserves the right to terminate any supplier agreement, immediately without liability, if the supplier cannot demonstrate that it is upholding the Supplier Guiding Principles. Additionally, RCCB has internal processes and procedures to help confirm that employees and suppliers meet our standards, including internal audits, measurement of key performance indicators and customer business reviews.


Beginning in 2018, RCCB will conduct mandatory training for employees responsible for sourcing decisions on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products. Further, RCCB requires that all employees annually certify compliance with the Reyes Holdings’ Guidelines for Business Conduct. This statement is made on behalf of Reyes Coca-Cola Bottling, L.LC.