California Transparency in Supply Chains Act of 2010

On September 30, 2010, the Governor of the State of California approved the California Transparency in Supply Chains Act of 2010 (the "Act"), which requires companies to disclose the efforts they have made and measures they have implemented to eradicate slavery and human trafficking from their respective supply chains. In doing so, the Act is designed to help consumers seek and purchase products from companies that "responsibly manage their supply chains," which in turn will "improve the lives of victims of slavery and human trafficking.” RockTenn supports the goals of the Act and strives to be a good example with respect to human rights and labor practices throughout our business activities.

RockTenn makes the following efforts in support and compliance with the Act:

• RockTenn reserves the right to perform verifications of its products supply chain to evaluate and address the risks of human trafficking and slavery.

• RockTenn reserves the right to verify its supplier’s compliance with the Act by utilizing an audit process conducted by an independent third party.

• RockTenn reserves the right to require any of our supplier’s to certify that the materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country in which they do business.

• RockTenn’s business practices are governed by integrity, honesty and full compliance with all applicable laws. RockTenn employees worldwide uphold our standards and strive to ensure that the reputation of RockTenn remains one of the Company’s most important assets. RockTenn will continue to promote these principles and take appropriate action should an employee, supplier or contractor fail to uphold our standards.

• RockTenn strives to keep the appropriate employees, including those in our sourcing and procurement departments, knowledgeable on and attentive to these compliance concerns. RockTenn commits to continue to evaluate its training programs.

 

RockTenn will continue to evolve and adapt to a changing world and intends to continue to operate with ethical integrity, accountability and in full compliance with all applicable laws.