Disclosure Statement pursuant to the California Transparency in Supply Chains Act of 2010

Hemlock Semiconductor Operations LLC (“HSC”) is committed to conducting business with honesty and integrity, in compliance with all applicable laws and regulations, and adherence to the highest legal and ethical standards. Our company commitment is detailed in our Code of Business Conduct (PDF). Through this Code of Business Conduct, as well as our Code of Business Conduct for Suppliers, HSC requires its employees and suppliers to exhibit these same ethical standards.

In accordance with the California Transparency in Supply Chains Act of 2010, companies must disclose measures they use to track possible slavery and trafficking in their supply chain, so that consumers may make informed decisions about the products they purchase and the companies they support. The following summary describes HSC’s efforts to address the five specific topics from the Act related to human trafficking and our product supply chains:

Verification – HSC conducted a risk assessment on the basis of the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor. We have determined that the company does not directly purchase goods identified as being at risk. HSC has an assessment process to identify such risk.

Audits – HSC determined that it does not directly purchase goods identified at being of risk for use of child or forced labor, therefore, HSC does not audit suppliers in its supply chain for compliance with the company’s standards for trafficking and slavery. However, should we become aware of a potential issue about any form of forced labor, human trafficking or slavery by our suppliers or vendors, then we will conduct an investigation and/or audit.

Certification – HSC’s Procurement Team oversees supplier selection and qualification and only engages with companies who are qualified and approved in accordance with this process. We regularly review and update our policies and practices in order to maintain high standards. The standard terms and conditions that are part of our purchase orders for direct purchased materials include requirements regarding adherence to anti-slavery and human trafficking laws.

Internal Accountability – HSC maintains company policies regarding accountability that include compliance with all applicable laws. Any employee found to be in violation of our policies is subject to disciplinary action, up to and including employment termination.

Training – HSC conducts training for employees who have direct responsibility for supply chain management on applicable laws, including those relating to human trafficking and slavery prohibitions. In addition, all HSC employees receive training in the company’s ethics policies and business code of conduct.