California Transparency in Supply Chains Act of 2010 Disclosure

The information below is provided to comply with the California Transparency in Supply Chains Act of 2010. The Act requires certain companies doing business in California to disclose their efforts to eradicate slavery and human trafficking from the direct supply chains for their products.

At Verso Corporation, one of our core values is “ethics and integrity.” Our Code of Conduct requires that we – the company and our employees – maintain a high level of ethics and integrity and do what is right. Our Code of Conduct specifically requires us to comply not only with the letter, but the spirit, of the laws that apply to us. That includes laws prohibiting slavery and human trafficking. We require our employees to read and sign the Code of Conduct and participate in periodic training and testing concerning its contents. We do not require our employees to engage in training that specifically pertains to slavery and human trafficking. If an employee responsible for sourcing materials for our products were to suspect a supplier of being involved in slavery or human trafficking, the employee would have a responsibility under the Code of Conduct not to ignore such suspicion, but to take action appropriate to the employee’s position at our company. Our Code of Conduct is available for review at www.versoco.com, on the “our company” page at the “governance” link.

We manufacture our products entirely within the United States. Accordingly, we must comply with the United States federal and state laws that apply to us, including labor laws. Our facilities and operations are subject to periodic audits by our internal audit team, which audits our compliance with laws and our internal policies, including labor laws and our Code of Conduct. We do not maintain separate internal audit or accountability standards or procedures pertaining to slavery and human trafficking. We do not audit our direct suppliers to determine if they engage in or permit slavery and human trafficking. We are confident that, at present, it is unnecessary to implement any such measures, because we have assessed (without third party assistance) our direct supply chains and consider remote the risk that our direct suppliers use or permit the use of slave labor or trafficked humans to produce and supply goods to us, for the following reasons:

  • The materials used in our products are primarily sourced from countries where there are laws and considerable social restraints against slavery and human trafficking.
  • Many of our direct suppliers are large, reputable companies that conduct substantial business in the United States. If any of these suppliers were to be involved in slavery or human trafficking, the discovery of such activity would likely be extremely damaging to the supplier. The supplier would face potential legal liability, harm to its reputation and lost customer relationships. We view this potential business damage to be a strong deterrent to involvement by our direct suppliers in slavery or human trafficking.
  • We require our direct suppliers to agree to comply with all applicable laws by entering into written contracts with us or accepting the terms and conditions of our purchase orders, but we do not require them to certify such compliance. If a direct supplier were to violate laws against slavery or human trafficking in supplying goods to us, we would consider it a material violation of the supplier’s agreement with us.

In connection with our ongoing sustainability and social responsibility initiatives, we may in the future implement additional measures that target the eradication of slavery and human trafficking from our direct supply chains.