California Transparency in Supply Chains Act Disclosure

Diamond Foods takes responsibility for continually improving our processes, practices and actions to maintain high standards in the ethical sourcing of commodities and materials associated with the manufacturing of our products. Diamond's compliance program encompasses verification, audit, certification, internal accountability standards, and training.

1) Verification of product supply chains to evaluate and address risks of human trafficking and slavery.
We require suppliers and brokers to provide annual written certification that they do not conduct business with, or have commercial relationships with any supplier who uses child or forced labor or otherwise breach good labor practices. In addition, from time to time, we engage third party firms to perform spot audits of suppliers to review compliance with these requirements.

2) Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.
In addition to our own audits, Diamond engages third party firms from time to time to assist with independent and unannounced child labor, fair wage, health and safety and overall employee environment inspections and to secure verification and certification against these requirements from suppliers who do business with Diamond Foods.

3) Requires direct suppliers to certify that materials incorporated into products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Diamond is implementing an annual certification process for suppliers showing their compliance with all applicable laws preventing the employment or benefit from child or forced labor.

4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Diamond administers internal controls and holds accountable all employees and brokers who represent the company in sourcing and procuring materials associated with the production of our portfolio of products.

5) Provides company employees and management, who have direct responsibility for supply chain management, training on mitigating risk with respect to ethical sourcing.
Diamond provides employees responsible for supply chain management and procurement with on-going opportunities to update the company's practices with respect to ethical sourcing. Diamond Foods' supply chain personnel participate in industry trade groups, on-line industry and academic programs as well as benchmarking practices against those of companies in the food industry.