Transparency in Supply Chains Act of 2010

On January 1, 2012, Senate Bill 657, The California Transparency in Supply Chain’s Act of 2010, California Civil Code Section 1714.43 (the “Act”) became effective. The Act requires companies to disclose their efforts (if any) to ensure that their supply chains are free from slavery and human trafficking. Buca Restaurants 2, Inc., a Minnesota corporation (“Buca” or “Company”), is a retail seller as that term is defined in the Act. The Company maintains a valuable reputation in the business community for honesty and fair dealing by acting ethically and in accordance with the laws applicable to our business. It is the expectation of the Company that each of our suppliers will likewise conduct their businesses in a legal and ethical manner. As a Company philosophy, Buca strongly opposes any and all illegal and unethical treatment of people, including any acts of forced labor, slavery or human trafficking. As required by the Act, Buca hereby discloses our efforts to eradicate slavery and human trafficking from our direct supply chain:

1. We do not engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery.

2. We do not conduct audits of suppliers to evaluate supplier compliance with company standards against trafficking and slavery in supply chains.

3. From time to time, we may request that our direct suppliers certify (i) they are aware of the need to comply with all applicable federal, state and local laws which prevent forced labor, slavery and human trafficking; and (ii) that their products are made in compliance with the laws regarding forced labor, slavery and human trafficking of the countries in which the suppliers are doing business.

4. We do not maintain internal accountability standards and procedures for employees failing to meet company standards regarding forced labor, slavery and human trafficking.

5. We will commence implementing a process for developing training regarding forced labor, slavery and human trafficking, with a particular focus in mitigating risks within the supply chains of products, for all Company employees who have direct responsibility for supply chain management.

Buca has a Code of Business Conduct and Ethics (the “Code”) that applies to all Buca employees. The Code requires compliance with the laws, rules and regulations of each state in which Buca does business, which would include all applicable laws regarding forced labor, slavery and human trafficking. In addition, the Code obligates all Buca employees to act in every respect with honesty, integrity, and a strong commitment to the highest standard of ethics.