CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT OF 2010

Panda's standard agreement for its food sourcing suppliers does not require suppliers to comply with applicable labor laws, although Panda is considering doing this in 2012. Panda, however, conducts annual assessments of its food sourcing suppliers. In addition, Panda expects to expand this assessment to obtain additional information about these vendors' activities related to the California Transparency in Supply Chains Act of 2010, including, where appropriate, preliminary risk assessment and supplier assessment questions, and later steps may take the form of requests for certification and/or audits. Panda primarily utilizes a third party for verification and audit processes. Panda also expects to evaluate whether supplemental training and/or changes in accountability standards and procedures for employees and/or contractors are appropriate.