California Transparency in Supply Chains Act Disclosure Statement

Direct Energy, together with its affiliated companies, is one of the largest providers of electricity, natural gas and energy related services in North America, with operations and employees throughout the United States and Canada. Direct Energy has developed business principles and codes of conduct for responsible corporate procurement. Direct Energy is committed to conducting business with integrity in a fair and professional manner and expects its business partners and suppliers also to adhere to responsible, ethical and humane practices wherever they operate around the world.

Pursuant to the California Transparency in Supply Chains Act, Cal. Civ. Code ยง1714.43 et seq., the following information discloses the efforts of Direct Energy to eradicate slavery and human trafficking from its direct supply chains:

Supply Chain Verification

Our suppliers are expected to comply with all applicable U.S. federal, state and local laws, including those that address forced labor, slavery and human trafficking. Should Direct Energy be informed of an issue with a supplier, Direct Energy reserves the right to request remediation of such issues.

Supplier Audits & Certifications

As part of its efforts, Direct Energy utilizes third party consultants specializing in supply chain risk and compliance to assist us in assessing suppliers for and mitigating against any conduct that contradicts our values. Currently, Direct Energy neither requires certification of materials by our suppliers nor routinely audits every supplier. Direct Energy prefers, where possible and practical, to source from domestic suppliers, and expects all suppliers to abide by applicable federal, international and local laws, rules, and regulations in the manufacture and distribution of materials supplied.

Supplier Accountability Program

Direct Energy works to develop and maintain business relationships with suppliers, who share our commitment to conduct business in a responsible and ethical manner in compliance with applicable laws. If Direct Energy becomes aware of actions or conditions not in compliance with law or with Direct Energy's commitment to the rights of workers to freely choose employment, Direct Energy reserves the right to request remediation or, in some cases, to terminate, our relationship with any such supplier(s).

Training

All Direct Energy employees are required to comply with our Code of Conduct, which includes provisions to ensure that Direct Energy complies with all applicable laws. Professionals in Direct Energy's Legal and Procurement departments monitor best practices among industry peers and as suggested by government authorities. Company practices in regard to supply chain, including training, are based on risk and legal requirements, and are directed by Direct Energy's Legal and Procurement professionals.


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