California Transparency in Supply Chain Disclosure

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Last modified and effective as of May 11, 2020

Clearwater Paper Corporation and our wholly owned subsidiaries (collectively, “Clearwater Paper”) are committed to conducting our business activities and transactions with the highest level of integrity and ethical standards and in accordance with applicable law. As part of our commitment to ensuring that our supply chain reflects our values and respect for fair labor practices, we have adopted a Supplier Code of Conduct (the “Supplier Code”) which establishes the minimum standards that must be met by any supplier that directly supply products or services to Clearwater Paper (“Supplier”). Our Supplier Code requires our Suppliers to obey all applicable laws related to forced labor, child labor, fair labor practices and human trafficking and slavery. Additionally, as part of our commitment to ensuring that our supply chain reflects our values and respect for human rights, we have adopted a Human Rights Policy (“Human Rights Policy”) which expressly applies to our Suppliers and establishes the minimum standards we are committed to meeting to prevent, identify and mitigate adverse human rights impacts of our operations and value chain.

The California Transparency in Supply Chains Act of 2010 (the “Act”) requires that certain manufacturers and retailers disclose their efforts to eradicate slavery and human trafficking from the supply chain. This disclosure under the Act describes Clearwater Paper’s efforts to seek business relationships with Suppliers who share our values and meet our standards.

Supply Chain Verification. We will conduct internal verifications to evaluate and address risks of human trafficking and slavery among our product supply chains including the requirement that our Suppliers acknowledge and agree to ongoing compliance with our Supplier Code through our standard agreements and purchase order terms and conditions.

Supplier Audits. We will conduct audits of certain Supplier’s that provide materials incorporated into our products to evaluate compliance with the Supplier Code and Human Rights Policy concerning the use of human trafficking and slavery. The audits may be conducted either by our internal resources or external third-party resources. If necessary, the audits may include unannounced independent third-party audits; however, at this time we do not believe that the risk in our supply chain is significant enough to require unannounced audits.

Supplier Certifications. We pre-screen our new Suppliers for compliance with applicable human trafficking and slavery laws. In addition, as part of our terms and conditions of purchase, we require our Suppliers to certify that materials incorporated into its products comply with the laws regarding slavery and human trafficking of the country in which they are doing business. We also utilize several third-party certification standards including the Forest Stewardship Council® and the Sustainability Forestry Initiative® that provide a third-party certification that the raw materials that we purchase are produced without the use of forced labor.

Accountability Standards and Procedures. Through our Code of Business Conduct and Ethics,Human Rights Policy and Supplier Code, we maintain internal accountability standards and procedures for our employees and Suppliers regarding compliance with both the letter and spirit of all applicable laws including laws related human trafficking and slavery. Additionally, our Supplier Code of Conduct provide us with the ability to terminate agreements and other contractual relationships with our Suppliers for noncompliance. Violations are handled on a case-by-case basis.

Training. We will provide specific training related to identifying and reporting human trafficking and slavery for those employees and management responsible for supply chain management.