California Transparency in Supply Chains Act

United Copper Industries is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such manner. We will not tolerate the involvement of our suppliers in human trafficking and slavery. Although we do not maintain a formal verification, audit or certification process with respect to our suppliers’ compliance with laws specifically related to human trafficking and slavery, we will quickly investigate any reports alleging human trafficking and slavery in our supply chain, and we will take action against any supplier that we find to have acted improperly in this regard.

We have a long-standing commitment to conduct our business in compliance with all applicable laws and in accordance with the highest ethical principles. Our Code of Business Conduct and Ethics prescribe certain values and principles to which we have committed our business. We provide each of our employees and officers with a copy of our Code of Business Conduct and Ethics and require that they adhere to the principles set forth therein, including complying with the laws of the jurisdictions in which we operate. A violation of our Code of Business Conduct and Ethics may result in penalties, including disciplinary action and termination.

From time-to-time we provide training for our employees and management on various topics, including business ethics and compliance with laws applicable to our business. While we do not provide specific training on human trafficking and slavery, our Code of Business Conduct and Ethics explains that if an employee needs guidance with respect to a legal or ethical dilemma, such person should consult with his or her supervisor or contact our Nominating and Corporate Governance Committee chairman, in accordance with our Whistleblower Policy, depending on the specific circumstances.

We take the issues of slavery and human trafficking very seriously and will continue doing our part by responsibly managing our supply chains in an effort to eradicate human trafficking and slavery.