Corporate Code of Ethics

We are committed to conducting our business with integrity and the pursuit of excellence in all that we do. Our management team and our Board of Directors are committed to honesty and compliance with all laws, rules, regulations and corporate policies that apply to our business, and we expect the same commitment from our employees, consultants, independent business owners, vendors and service providers. In particular, we are committed to acting responsibly, safely and with transparency in our interactions with independent business owners, service providers, vendors and other stakeholders in our daily operation.

Compliance Hotline

NatureAve has established various methods of confidential communication for our employees, vendors, IBOs and others to report suspected violations of laws, rules, regulations or company policies. Where permitted by local laws, anonymous reporting is available through our “contact us” link  or through the toll-free numbers:

888-803-3088

Comprehensive Compliance Program

As part of NatureAves’ continuing commitment to corporate compliance, NatureAve declares that, to the best of its knowledge, and based on a good faith understanding of the statutory requirements of DSA, it has adopted a Comprehensive Compliance Program as mandated by California law. To the best of our knowledge, as of August 1, 2016, NatureAve believes that it is in compliance with its Comprehensive Compliance Program and its good faith understanding of the requirements of DSA.

Code of Conduct

On January 2, 2015, the Board of Directors of NatureAve amended and restated the Code of Conduct that applies to all of NatureAve’s directors, officers and employees (“Covered Personnel”). The principal purpose of the amendment and restatement was to provide additional guidance to Covered Personnel regarding the available channels for reporting of possible legal or policy violations, to bring certain provisions of the Code of Conduct into conformity with certain legal requirements in jurisdictions outside the United States and other existing policies and procedures of the Company and to make certain other technical and administrative changes. The revisions to the Code of Conduct did not relate to or result in any waiver, explicit or implicit, of any provision of the Code of Conduct in effect prior to its amendment and restatement.

Supply Chain Transparency

NatureAve and its subsidiaries (“NatureAve” or “the Company”) are committed to operating our global business with integrity and upholding a high level of ethical conduct among our employees and business partners. We expect suppliers which provide materials for use in our tangible goods for sale (“Product Suppliers”) to adopt sound human rights practices, to treat workers fairly, with dignity and respect, and in all cases to eliminate human trafficking and slavery in their workplace.

Verification: NatureAve has existing procedures for assessing our Product Suppliers and is in the process of enhancing these procedures to include steps for evaluating whether our Product Suppliers comply with applicable laws related to eradication of human trafficking, slavery and illegal child labor. Our Supply Chain and Quality Assurance teams oversee these verification procedures using an internally-developed multi-part assessment. In addition, NatureAve has adopted written Supplier Standards, and requests that our Product Suppliers certify that they comply with applicable laws concerning human trafficking, slavery and illegal child labor in the countries in which they do business.

Audits: NatureAve conducts periodic and regular announced audits of its Product Suppliers to evaluate their compliance with Jazz’s policies and applicable legal and regulatory requirements. NatureAve typically conducts such audits using its own personnel, although it reserves the right to engage an independent third-party auditor. NatureAve’s current Contract Manufacturer Assessment Guidelines establish procedures for audits of potential and existing Product Suppliers, including their training, experience and qualifications, adherence to legal and regulatory requirements, and evaluation of the suppliers’ compliance with quality systems. In particular, NatureAve expressly addresses human trafficking, slavery and illegal child labor in its auditing protocol for Product Suppliers. NatureAve tracks any observations and/or non-compliance in its Audit Follow-Up & Close-Out procedures to ensure that instances of non-compliance are properly re-mediated.

Materials: NatureAve has adopted procedures that require Product Suppliers to certify that materials incorporated into NatureAve’s products comply with the laws regarding human trafficking, slavery and illegal child labor in applicable countries.

Accountability Standards: NatureAve is in the process of establishing internal accountability standards and procedures, including disciplinary action for its employees and contractors with procurement responsibilities who fail to meet NatureAve’s standards regarding identification and elimination of human trafficking, slavery and illegal child labor in its supply chain.

Training: NatureAve is in the process of developing training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks of human trafficking, slavery and illegal child labor within the supply chain.