Corporate Disclosure in Compliance with SB 657 The California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 (SB657) effective in the State of California on January 1, 2012 seeks the elimination of slavery and human trafficking from product supply chains by requiring companies to disclose their efforts, if any, to ensure that their supply chains are free from slavery and human trafficking. Kaneka Americas Holding, Inc. is committed to fair employment practices and to following applicable employment law wherever it has operations, specifically those applicable laws that prohibit human trafficking or forced labor. We also expect our suppliers and vendors to conduct themselves in compliance with all applicable laws, including those laws prohibiting forced labor and human trafficking. We do not currently engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery, conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, require direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business, maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking, or provide employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery.