CA Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2010 requires certain disclosures by certain retail and manufacturing companies doing business in California, pertaining to the disclosing companies' efforts, if any, to address the issues of slavery and human trafficking in their supply chains. Pool Corporation together with its subsidiary and affiliate entities (hereinafter collectively "Pool") is a wholesale distributor of swimming pool, spa and related leisure product merchandise. Notwithstanding, Pool hereby shares this information on the number of steps it takes to further its commitment to fair employment practices and issues pertaining to slavery and human trafficking.

Pool has adopted a Supplier Code of Conduct and requires in its standard terms of purchase that all of its suppliers comply with applicable laws, rules and regulations, including those pertaining to human trafficking and slavery. Pool is in the process of having new and existing suppliers execute and agree to these forms. These documents also allow Pool to conduct audits (either itself or through third parties) to gauge suppliers' compliance with the applicable laws concerning slavery and human trafficking. Any such audits may be either announced or unannounced. Pool does engage in verification of product supply chains by requesting information from its vendors pertaining to issues of human slavery, trafficking and conflict minerals. Pool will not knowingly purchase products from any supplier which Pool has confirmed utilizes slave labor or engages in human trafficking.

Pool requires that all of its supply chain management employees are trained on Pool's Supplier Code of Conduct and the provisions of Pool's standard terms of purchase that address human slavery and trafficking, with such training including the identification of, response to and mitigation of those risks, as well as Pool's corporate position of not knowingly permitting or enabling human slavery and trafficking.