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NEENAH PAPER, INC.
Disclosure Under the California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (the “Act”) requires certain companies manufacturing or selling products in California, including Neenah Paper, Inc. (“Neenah”), to disclose their efforts (if any) to address the issues of human trafficking and slavery and efforts to eradicate each of these from their direct supply chain. To this end, Neenah has developed and implemented the Neenah Paper, Inc. Ethical Purchasing Policy (the “Ethical Purchasing Policy”), which among other issues, sets out the requirements and expectations Neenah has for its suppliers relating to the issues of slave labor and human trafficking. The following is the disclosure under the Act for Neenah and its subsidiaries:

  1. Neenah periodically evaluates, using both internal resources and through the use of independent third parties, its product supply chains and addresses any risks of human trafficking and slave labor. Neenah requires that suppliers acknowledge and agree to the requirements of the Ethical Purchasing Policy through its purchase order terms and conditions;
  2. Neenah will periodically conduct audits to evaluate supplier compliance with the Ethical Purchasing Policy, which includes compliance with Neenah’s policy concerning the use of human trafficking and slavery. The audits may be conducted either by Neenah internal resources or external third party resources. If necessary, the audits may include unannounced independent third party audits; however, at this time Neenah does not believe that the risk in its supply chain is significant enough to require unannounced audits;
  3. As part of its terms and conditions of purchase Neenah will obtain certifications from its direct suppliers that materials incorporated into its products comply with the laws regarding slavery and human trafficking of the country in which they are doing business;
  4. Through its Code of Business Conduct and Ethics and Ethical Purchasing Policy Neenah maintains internal accountability standards and procedures for employees or contractors regarding slavery and trafficking. Additionally these policies provide Neenah with the ability to terminate agreements and other contractual relationships with suppliers for noncompliance with these required standards;
  5. Neenah will provide specific training related to identifying and reporting human trafficking and slavery for those employees and contractors linked directly to supply chain management. Neenah’s Code of Business Conduct and Ethics, which is issued to all Neenah employees, clearly states the commitment of all Neenah employees to compliance with all applicable laws and regulations in the conduct of our business activities. This extends to laws regarding slavery or human trafficking in the countries in which we do business. Failure to comply with Neenah’s Code of Business Conduct and Ethics can result in disciplinary action and or termination of employment.
For additional detailed information relating to this disclosure or for additional information concerning Neenah’s supply chain policies please refer to the Neenah Paper Ethical Purchasing Policy located at www.neenah.com/aboutus/Neenah Ethical Purchasing Policy.pdf

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