California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act went into effect January 1, 2012. It requires manufacturers doing business in California with worldwide sales exceeding $100 million to disclose their efforts to eradicate slavery and human trafficking from their direct supply chain.

MGC Pure Chemicals America, Inc. (MPCA) has internal policies and practices to address the issues of slavery, human trafficking and child labor. Our Company Handbook covers our policies and practices. We also base our policies and practices on the Electronics Industry Citizenship Coalition (EICC) which prohibits the use of forced, bonded, indentured labor or involuntary prison labor. We work closely with our supply chain to help create an environment where workers have the right to freely choose employment and the right to associate freely and are ensured no harsh, discriminatory or inhuman treatment.

Verification

MPCA is committed to fair labor practices within our Company and supply chain. We audit our key product suppliers using our Company policies and practices and the EICC standards and take seriously all forms of non-conformance. Internally we evaluate the potential risks for slavery and human trafficking in our supply chain. Our key suppliers are located in the United States. We do not have any goods on the U.S. Department of Labor’s list of goods identified as vulnerable to forced labor.

Each year we identify all of our key suppliers. We will collect information from the suppliers annually.

Audits

Supplier audits are conducted by MPCA personnel, not by a third party, and may or may not be announced. Internally we evaluate the potential risks for slavery and human trafficking in our supply chain. We audit our key product suppliers using our Company policies and practices and the EICC standards and take seriously all forms of non-conformance. Our key suppliers are located in the United States. We do not have any goods on the U.S. Department of Labor’s list of goods identified as vulnerable to forced labor.

We will collect information from the suppliers annually and we conduct audits every three years with a third of key suppliers completed each year.

Certification

While we currently do not require our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries they do business in, a number of our key suppliers are in compliance with the California Transparency in Supply Chains Act. We are looking at requiring our direct key suppliers to provide certification to above California law in the future.

Internal Accountability

Non-compliance with our Company standards regarding compliance issues and including slavery and human trafficking can result is disciplinary action up to and including discharge. Corrective actions can be implemented to become in compliance again. There is a team of internal auditors who are auditing employees and Company for any compliance violations. Contractor companies are reviewed when initially contracted for work on site.

Company Handbook does cover Fair Labor requirements. We do check how internal communication procedures takes place regarding any issues between the company and employees. If and when our company finds employee or contractor compliance issues, action is taken and corrective action is required under our Corrective Action procedure requirements.

Training

Annual third-party Ethics training is conducted by our legal firm for all Management including those who have direct responsibility for supply chain management. This training is given to President, Executive VP, VP, CFO, CTO, Plant Manager and all managers. This training has been conducted for a number of years. However this training does not specifically cover slavery and human trafficking. We do not provide this training to our contractors.

May 2015