CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT STATEMENT

Fry Steel Company (“Fry Steel” or “we”) fully supports California’s efforts to protect human rights and enforce ethical labor practices under the California Transparency in Supply Chains Act of 2010 (SB 657) (the “Act”). Fry Steel is proud of its reputation and record for integrity and respect in dealing with our own employees, and expects nothing less of our suppliers in their dealings with their own workforces.

The Act requires companies that conduct business in California to disclose efforts to eliminate slavery and human trafficking in supply chains. As a subsidiary of Reliance, Inc., Fry Steel has adopted the Reliance, Inc. Employee Code of Conduct pursuant to which our employees are required to comply with all laws, rules and regulations in the jurisdictions in which we conduct our business, including laws related to the prohibition of human trafficking and slave labor.

Fry Steel believes the risk of slavery and human trafficking in its supply chains is low. Accordingly, Fry Steel does not currently engage in verifications of product supply chains to evaluate and address risks of human trafficking and slavery, conduct audits of suppliers to evaluate supplier compliance with standards for trafficking and slavery in supply chains, require direct suppliers to certify that materials incorporated into our products comply with laws prohibiting slavery and human trafficking in the countries in which Fry Steel does business, maintain internal accountability standards and procedures for employees or contractors failing to meet standards regarding slavery and human trafficking, or provide training regarding human trafficking and slavery to employees and management having direct responsibility for supply chain management.  While our suppliers are not expressly required to certify that materials sold to Fry Steel comply with laws regarding slavery and human trafficking, they are generally required to comply with all laws, rules and regulations, including those related to the prohibition of trafficking and slave labor.

The Reliance, Inc. Compliance Hotline, where permissible under local laws, is available to all employees, directors and contractors of Fry Steel, as well as our business partners, their employees or their subcontractors. The Hotline, where permissible, enables the reporting of noncompliance by Fry Steel’s business partners, their employees or subcontractors.

Fry Steel expects all of its suppliers to conduct business with the highest levels of integrity and ethical standards, in a manner that respects human rights and in compliance with all applicable laws and regulations related to the prohibition of human trafficking and slave labor. Fry Steel reserves the right to immediately suspend or discontinue engagement with any supplier at any time and will take appropriate action if we suspect any supplier has violated any law or regulation related to prohibition of human trafficking and slave labor.