TracFone’s Anti-Slavery and Human Trafficking Disclosure

Pursuant to the California Transparency in Supply Chains Act.

TracFone Wireless, Inc. (“TracFone”) strives to conduct business in a manner that respects our TRAC Values – Trust, Respect, Accountability and Collaboration. Our TRAC Values not only govern the manner in which we act, but they are values we expect all our suppliers to follow. We believe that the TRAC Values have helped us become an ethical company and an advocate for human rights.

To that end, in 2017, we phased out our Vendor Code of Conduct, opting instead to require our vendors to abide by the same TracFone Code of Conduct that we require our directors, officers, employees and agents to follow. We believed then as we do now, that we are responsible for the products and services we provide, and we expect ethical conduct from our suppliers’ factories, to our retail stores, and everywhere in between.

The California Transparency in Supply Chains Act (“CTSC”) requires retailers and manufacturers above a certain size that are doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains. The below disclosures pursuant to the CTSC are aimed at providing information to consumers to allow them to make better, more informed choices about the products they buy from TracFone, and the manner in which TracFone combats slavery and human trafficking in its supply chain.

Verification

TracFone requires its suppliers to refrain from the direct or indirect use of forced labor or any forms of human trafficking and to ensure that they have ethical and human rights policies and appropriate complaints procedures to deal with any breaches of such policies. TracFone reserves the right to verify our suppliers’ compliance with the above warranty and reserves the right to use a third-party verifier.

Auditing

TracFone believes that dialogue and partnership can be an effective way to drive positive change and to address root cause issues that are persistent within the supply chain. TracFone also acknowledges that sometimes, dialogue is not adequate and an onsite, independent audit of our suppliers is the more appropriate avenue. Accordingly, TracFone reserves the right, upon reasonable notice, to audit our suppliers’ compliance with TracFone’s standards.

Certification

Through signing the agreements with TracFone, suppliers certify that all materials incorporated into products sold to TracFone comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Internal Accountability

TracFone requires all of its directors, officers, employees, agents and vendors’ to comply with TracFone’s Code of Conduct, which is available at www.tfethics.com. Suppliers, contractors and service providers are expected to act ethically and are required to comply with the TracFone’s Code of Conduct and TracFone’s Anti-Slavery and Human Trafficking Policy. As with all alleged violations of policy, we investigate issues and take the appropriate action up to and including termination or removal of directors, officers, employees and agents, and termination of agreements with vendors. We encourage employees and members of the general public to notify us of suspected violations of our Code of Conduct or violations of the Anti-Slavery and Human Trafficking Policy by filing a complaint at www.tracfone.ethicspoint.com .

Training

At TracFone, we believe that training and education is fundamental to fully integrating labor compliance and social responsibility into all purchasing decisions and to building a socially and environmentally responsible supply chain. All new hires are required to read TracFone’s Anti-Slavery and Human Trafficking Policy as part of their orientation.