California Supply Chain Act Disclosure

John B. Sanfilippo & Son, Inc. (“JBSS”) has a long history of operating with high ethical standards and integrity. We conduct business in accordance with all applicable laws and regulations. Mere compliance with the law does not encompass our entire ethical responsibility; rather it defines the minimum essential performance of our responsibilities. Our core commitment is much deeper and more encompassing. Across our business and supply chains, we are dedicated to upholding human rights and preventing forced labor.

The California Transparency in Supply Chains Act requires retailers and manufacturers to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains. Accordingly, this disclosure highlights our efforts to prevent forced labor within our organization and our supply chains through verification, audit, certification, internal accountability, and training. This disclosure applies to JBSS and any of its subsidiaries that are subject to the California Transparency in Supply Chains Act.

Verification

JBSS is committed to fair labor practices within our supply chains. Our subcontractors and vendors are subject to assessments or periodic inspections to ensure compliance with laws relating to employment and human rights, including prohibitions on forced labor and human trafficking. This practice is reflected in our Position on Upholding Human Rights.

Our verification process involves an annual survey sent to select suppliers regarding their programs for assuring that human trafficking, forced labor, and unlawful use of child labor do not exist in their supply chains. We do not currently use third-party verifiers.

Audit

JBSS does not currently conduct audits of our suppliers. The annual survey sent as part of our supplier verification process requests information about independent audits of foreign suppliers’ facilities, and we rely on the self-certification in our Supplier Code of Conduct to ensure compliance with our policies regarding forced labor and human trafficking.

Certification

Our Supplier Code of Conduct sets forth JBSS’s standards and expectations with respect to key areas of corporate responsibility for our suppliers and vendors and their respective subcontractors and agents. It is the policy of JBSS that suppliers must have management systems in place to support compliance with such Code, in addition to all applicable laws and regulations. We encourage our suppliers to implement their own written codes of conduct.

Specifically, in signing the Supplier Code of Conduct, JBSS suppliers self-certify that they are and will remain in compliance with the following relevant provisions while doing business with JBSS:

• Human Trafficking: JBSS strictly prohibits our suppliers from engaging in human trafficking-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using slavery, using force, fraud or coercion to subject a person to involuntary servitude, using bonded (including debt bondage) or indentured labor, or obtaining labor from a person by threats of serious harm to that person or another person.
• Child Labor: JBSS is committed to the elimination of the “worst forms of child labor,” as defined by ILO Convention 182, from our supply chain. We expect our suppliers to support and participate in industry efforts aimed at the elimination of such practices wherever they exist in the supply chain.
• Working Hours and Wages: Suppliers must provide wages at least equal to the applicable legal minimum wage and any associated minimum statutory benefits. If there is no legal minimum wage, suppliers must ensure that wages are at least comparable to those at similar companies in the local area or to prevailing industry norms. Working hours should reflect applicable legal norms and overtime hours should be paid at the legally mandated premium or at least at the same rate as regular hours worked if there is no mandated premium.
• Freedom of Association: Suppliers should respect employees’ right to freedom of association including the right to collectively bargain, consistent with local national laws and regulations and ensure that all employee relationships are of a voluntary nature.

Internal Accountability

JBSS is firmly committed to ensuring the health, safety, and welfare of our employees, as well as those who are employed within our supply chains.

As is set out in our Code of Conduct, each employee plays a critical role in ensuring the quality and safety of working conditions in each JBSS facility. In this regard, all aspects of our operations shall be conducted in strict compliance with all applicable health and safety laws and regulations, JBSS policies, and best practices pertaining to workplace safety. All employees, executive officers, and members of the Board of Directors are expected to:

• Adopt a proactive and cooperative attitude towards the health and safety of all JBSS employees, customers, suppliers, vendors and others working at or visiting our property, and
• Report promptly all on-the-job accidents, injuries, environmental incidents and concerns about unsafe working conditions to Human Resources or their supervisor.

Employees and agents of JBSS have many channels and avenues to report potential or alleged violations of our policies regarding labor conditions; these include our Internal Audit Department and EthicsPoint, the JBSS anonymous reporting system. Employees may also report possible violations to line management or human resources. No reprisal or retaliatory action will be taken against any employee or agent for raising concerns through these channels. JBSS will take appropriate disciplinary action for violations of our policies regarding forced labor and human rights, up to and including termination of employees, subcontractors, agents and vendors.

Finally, as is set out in our Supplier Code of Conduct, it is the policy of JBSS that suppliers must allow their employees and third party agents to raise issues or concerns without fear of retaliation. To that end, suppliers who learn or are aware of either (i) violations of the Supplier Code of Conduct by a JBSS supplier, or (ii) violations of law or policy by JBSS employees related to services provided to or contracts with JBSS, have an obligation and must direct and allow their employees and third-party agents to report such issues, concerns or conduct to JBSS. Such reports may be made to JBSS anonymously through EthicsPoint, the JBSS anonymous reporting system.

Training

To advance our commitments to the health, safety, and welfare of our employees, we conduct annual mandatory training for all employees covering food safety, workplace safety and various regulatory and compliance related subjects.

To help ensure heightened awareness, detection, prevention, and reporting of human trafficking, JBSS provides to our employees, managers and our third-party operators the following link to the Department of Homeland Security’s “Blue Campaign,” a national public awareness campaign designed to educate the public, law enforcement, and other industry partners about how to recognize and appropriately respond to indicators of human trafficking.