Policy Statement - Anti-Human Trafficking Disclosure Statement
Anti-Human Trafficking Disclosure Statement
Moog is committed to fair employment practices, including compliance with applicable U.S. and international laws that prohibit child and forced labor and has adopted the following policy statement:
“Moog will not tolerate Trafficking in Persons in our global operations, nor engage in contracting or subcontracting with other entities that are Trafficking in Persons. We will endeavor to meet or exceed all regulatory requirements related to Combating Trafficking in Persons adopted by the Government of the United States, as well as such similar requirements as are adopted by the respective governments of other states and countries where we do business.”
Moog’s expectation is that its suppliers will produce products in an ethical and socially responsible manner and that our suppliers should not use, or in any way, benefit from forced labor.
Moog Inc. is a worldwide designer, manufacturer and integrator of precision motion control products and systems. Moog Inc. is the parent company of many subsidiaries that are divided into 4 segments based operating groups: 1) Aircraft; 2) Components; 3) Industrial; and 4) Space & Defense. Moog’s 2016 worldwide revenues were in excess of $2 billion. Due to the breadth of Moog’s business operations, it is legally subject to the following: 1) Federal Acquisition Regulation (FAR) 52.222-50; 2) the California Transparency in Supply Chain Act; 3) the United Kingdom Modern Slavery Act; 4) the Trade Facilitation & Trade Enforcement Act of 2015; and 5) any pending or future laws pertaining to the awareness and elimination of human trafficking throughout the world to which Moog now, or in the future may become subject (all collectively referred to herein as the “Anti-Human Trafficking Laws”). Moog offers the following disclosure statement that has been approved by its Board of Directors to communicate what we are doing at Moog to promote compliance with worldwide Anti-Human Trafficking Laws.
In 2016, Moog adopted an Anti-Human Trafficking Compliance Plan. Key elements of this Plan include:
1. Statement of Business Ethics- Moog’s Statement of Business Ethics has been amended to reflect the above policy statement.
2. Training/Internal Accountability-By the end of 2016, all of Moog’s Supply Chain employees will be trained in Anti-Human Trafficking awareness and provided with resources to escalate concerns if such prohibited activity becomes known to them. In 2017, all current and new Moog associates will be trained on Anti-Human Trafficking as part of Moog’s annual training on the above linked Statement of Business Ethics. All such training shall reinforce that the consequences for employee violations of Moog’s Anti-Human Trafficking policy will result in disciplinary action up to, and including, termination. In a further attempt to increase employee awareness, each Moog location worldwide is posting employee awareness communications and hotline information for reporting of anti-human trafficking concerns.
3. Audit- Moog includes a contractual provision in its supply agreements requiring our suppliers to comply with anti-human trafficking laws and allowing Moog to audit them periodically for such compliance, although Moog does not currently conduct such audits. Our supply chain is also contractually required to make Moog aware of any forced labor issues that become known regarding it or its own sub-tier suppliers and they are required to flow down such anti-human trafficking provisions to sub-tier suppliers in applicable contracts. Lastly, Moog has the right to terminate its supply contracts if anti-human trafficking issues are found.
4. Certification-By contract, Moog has the ability to require its suppliers to answer a questionnaire disclosing the details of its own anti-human trafficking compliance program. In addition, while Moog does not currently seek such certification in the regular course of business, it has the contractual ability to require a certification from required suppliers that it has an anti-human trafficking compliance plan in place. Moog is not currently aware of any issues in its supply chain that would give rise to a violation of its Anti-Human Trafficking Compliance Plan.
5. Verification/Focus- Moog monitors regions and markets where anti-human trafficking are most prevalent and pays close attention to the portion of our supply chain in these areas. Such review reveals that the area of our supply chain most at risk for this type of prohibited activity is the supply of electronic components from Asia. To assist with such due diligence, Moog is negotiating with a third party who provides an analytic tool to provide Moog more visibility into its sub-tier suppliers. This will allow Moog to focus its audit and review activities on any suppliers that could be high risk or suspect. Moog is considering the option of utilizing an independent third party to perform unannounced audits on its behalf but does not currently employ an independent third party auditor for such purposes.
6. KPI’s- Key Performance Indicators Moog will review to measure effectiveness of performance will be: 1) number of questionnaires completed by supply chain; 2) number of reviews conducted on suppliers delineated as high risk and the results thereof; and 3) through direct communication with suppliers and Moog’s vendor approval process, gauging the overall understanding of Moog’s supply chain as to the importance of this issue and the effectiveness of their own compliance efforts.
For any questions related to the foregoing, kindly contact Randy Fahs at rfahs (at) moog.com.
John Scannell, Chairman & CEO Print Friendly Signature Copy
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