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California Transparency and Supply Chains Act of 2010 Disclosure Statement

Section 1714. 43 Disclosure

As set forth in its Code of Conduct, it is Stepan's policy to comply with all applicable foreign and domestic laws. Stepan Company has not yet adopted the programs or procedures required to be disclosed pursuant to the provisions of the California Transparency and Supply Chains Act of 2010 ("Act") including Sections 1714.43(c)(1)-(5). In 2012, Stepan will review its direct supply chain to assess risks, if any, in connection with slavery and human trafficking, and revise as appropriate, this disclosure.