California Transparency in Supply Chain Act

CA1714.43

Basic Working Conditions and Human Rights in Airtech’s Supply Chain 01/01/2012 Airtech takes the following actions to reduce the risk of human trafficking and slavery in Airtech’s supply chain:

1. Airtech engages in verification by evaluating the risk of human trafficking and slavery in Airtech’s direct (first tier) supply chain as described herein.
   • Verification is conducted by Airtech, not by a third party.
   • Airtech periodically conducts site visits of a representative sample of Airtech’s direct (first tier) suppliers. Airtech personnel who conduct such site visits are trained to evaluate the risk of human trafficking and slavery in Airtech’s supply chain.
   • If such evidence is discovered, Airtech personnel will report those findings to their management.


2. Airtech does not conduct audits of suppliers to evaluate their compliance with company standards for trafficking and slavery in supply chains.
   • Verification occurs as described in (1) and (3) of this disclosure.
   • Airtech does not verify through independent, unannounced audits.


3. Airtech does not require its suppliers to certify that the materials incorporated into the products they deliver to Airtech comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. However, Airtech includes a Compliance with Law clause in its subcontracts with its direct suppliers requiring supplier compliance with applicable statutes and government rules pertaining to human rights and eradicating human trafficking and slavery.
   • Specifically with regard to human rights, Airtech also includes a separate and distinct clause in its subcontracts with its suppliers entitled “CERTIFICATION CA1714.43”


4. Airtech maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. Basic Working Conditions and Human Rights in Airtech’s Supply Chain 01/01/2012
   • Airtech has adopted and enforces a similar “Non-Employee Code of Conduct” for contract hires who perform work for Airtech.
   • Compliance with the requirements of the Code of Conduct is expected behavior for Airtech employees. Violation of these requirements will result in appropriate corrective action.


5. Airtech provides human trafficking and slavery training of employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products.
   • Airtech managers provide awareness training to those Airtech employees with direct responsibility for supply chain management.
   • Such Airtech employees are directed to contact their managers for any concerns they have with the risk of human trafficking and slavery in Airtech’s supply chain.