California Transparency in Supply Chains Act of 2010 Disclosure

Chick-fil-A, Inc. (“CFA”) is committed to legal compliance and ethical conduct for itself and expects the same of its vendors. Thus, CFA’s policy is to only do business with vendors who have certified to CFA that their business practices are lawful, ethical and in compliance with the principles set forth in CFA’s Vendor Code of Conduct, and CFA expects its vendors to take steps to ensure the same of their own supply chains. Specifically, CFA will not conduct business with vendors employing persons under the age of 14, or in/under prison, indentured or bonded labor, or slave labor; benefitting from human trafficking; using corporal punishment or other forms of mental and physical coercion as a form of discipline; or providing or supplying goods or services tainted by any of the foregoing practices.

In accordance with the California Transparency in Supply Chains Act of 2010, CFA makes the following disclosures:

CFA requires its vendors to certify that their business practices are lawful, ethical and in compliance with the principles set forth in CFA’s Vendor Code of Conduct (including those provisions relating to human trafficking and slavery), and that they take steps to ensure the same of their own supply chains. To ensure accountability, CFA reserves the right to terminate its business relationship with any vendor who fails to provide such certifications or whose business practices, or the business practices of its own suppliers and subcontractors, are not lawful, ethical and in compliance with the principles set forth in CFA’s Vendor Code of Conduct. CFA also reserves the right to terminate its business relationship with vendors who fail to provide written confirmation to CFA that they have a program in place to monitor their suppliers and subcontractors for compliance with law, good ethics, and the principles set forth in CFA’s Vendor Code of Conduct. CFA reserves the right to conduct verification and audits (including third-party verification and audits) of its suppliers regarding human trafficking and slavery. CFA has conducted general audits of certain of its suppliers, and has not observed violations with respect to human trafficking or slavery issues. CFA is currently considering whether and how to best use third-party supply chain verification and independent unannounced audits with its suppliers. CFA provides company employees and management who have direct responsibility for supply chain management with training on CFA’s business practices, vendor requirements, and CFA’s Vendor Code of Conduct, including those provisions relating to mitigating risks of human trafficking and slavery. Employees and management failing to meet CFA standards regarding slavery and trafficking are subject to disciplinary action.