California Transparency in Supply Chains Act of 2010 - Disclosure

The Walgreen Co. Vendor Responsibility Program and third parties engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Vendors doing business with Walgreen agree that they shall not use any form of convict, bonded, forced, indentured or other illegal labor, or any form of slavery or human trafficking. Vendors also agree to require the same of any subcontractor used in the manufacturing of Walgreen products or product components. Based on the results of risk assessment evaluations, Walgreen engages third party audit firms to conduct audits to evaluate compliance with these requirements. The audits are conducted on both an unannounced and announced basis. Walgreen employees directly responsible for supply chain management in the California market are required to complete Vendor Responsibility Program training which includes awareness of human trafficking and slavery risks in the supply chain of products and ways to mitigate those risks. Walgreen maintains accountability standards and procedures for any employee, contractor and/or vendor who is determined to have failed to meet these requirements.