Supply Chain Human Rights Compliance

Moog is committed to fair employment practices, including compliance with applicable U.S. and international laws that prohibit child and forced labor.  We endeavor to maintain open and fair business dealings in the selection of sources of supply on the basis of quality, price, services offered, and adherence to business ethics policies that are consistent our own standards. Moog’s business relations expectations are that its suppliers will produce products in an ethical and socially responsible manner.

With respect to contracts for goods and services to be supplied to the U.S. Government, Moog includes Federal Acquisition Regulation (FAR) Clause 52.222-50, “Combating Trafficking in Persons” in its subcontracts, including commercial item subcontracts.

Moog’s standard terms and conditions of purchase require that all supplied goods and services be produced and furnished in compliance with all applicable laws, including those related to equal employment opportunity, wages, hours and conditions of employment. A material violation by a supplier or potential supplier of applicable laws or regulations regarding human trafficking or slavery will not be tolerated by Moog and will result in Moog’s discontinuing to use the supplier as a source of supply until the violation has been corrected.

California Transparency in Supply Chain Act of 2010
The California Transparency in Supply Chain Act requires manufacturers doing business in California to disclose to consumers their efforts to eradicate slavery and human trafficking from its supply chains.  
In reference to the specific disclosures called for in the Act, the following additional information is provided:

1. As described above, Moog engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. Moog does not currently use an independent third party to conduct verifications.

2. Moog does not currently conduct audits of suppliers to evaluate supplier compliance with Moog standards for trafficking and slavery in the supply chain.  

3. Moog does not currently require direct suppliers to certify that materials incorporated into products sold by Moog comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

4. As reflected in its Statement of Business Ethics and other legal compliance standards imposed on its employees, Moog maintains internal accountability standards and procedures for employees who fail to meet company standards regarding slavery and human trafficking.  In the context of the flow down of FAR requirements on U.S. Government contracts, Moog extends those standards to subcontractors and suppliers. In addition, Moog requires each of its suppliers, as a material contract term, to comply with all laws and regulations applicable to the supplier’s operations and the products supplied to Moog.

5. Moog provides its employees and managers, who have direct responsibility for supply chain management, training on human trafficking and slavery, but does not currently place particular emphasis on mitigating risks of human trafficking and slavery within the supply chain.

02/2012