Policy Statement - Anti-Human Trafficking Disclosure Statement
Modern Slavery / Anti-Human Trafficking (together “Modern Slavery”) Disclosure Statement
This statement constitutes a slavery and human trafficking statement and is made pursuant to the California Transparency in Supply Chain Act and section 54 of the Modern Slavery Act 2015 (“MSA”) by Moog Inc. and its subsidiaries including but not limited to Moog Controls Limited and its subsidiaries as well as other Moog Inc., subsidiaries located in the UK and listed below (together “Moog UK”, “we”, “our” or “us”) for the year ended 30 September 2018.
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, including Moog UK (together the “Moog Group”), that are currently divided into three segments-based operating groups:
1. Aircraft Controls;
2. Industrial Systems; and
3. Space and Defense Controls.
The Moog Group’s 2018 revenues were in excess of $2.7 billion. Due to the breadth of the Moog Group’s business operations, it is legally subject to the following:
1. the U.S. Federal Acquisition Regulation (FAR) 52.222-50;
2. the California Transparency in Supply Chain Act;
3. the MSA;
4. the U.S. Trade Facilitation & Trade Enforcement Act of 2015; and
5. any pending or future laws pertaining to the awareness and elimination of modern slavery throughout the world to which the Moog Group now, or in the future may become subject,
(together the “Modern Slavery Laws”).
Our Supply Chain
Moog UK’s business serves a wide variety of products, solutions and services. This exposes Moog UK to a large and diverse supply chain. We are nonetheless committed to taking appropriate steps designed to ensure there is no modern slavery in our supply chain. Our expectation is that all of our 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 labour.
The Moog Group is committed to fair employment practices, including compliance with Modern Slavery Laws, and has adopted this policy statement:
“Moog will not tolerate modern slavery in our global operations, nor engage in contracting or subcontracting with other entities that are engaged in modern slavery. We will endeavour to meet or exceed all regulatory requirements related to combating modern slavery 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.”
We have a Modern Slavery Compliance Plan. Key elements of this Plan include:
1. Statement of Business Ethics: our Statement of Business Ethics reflects the above policy statement.
2. Training / Internal Accountability: our employees are trained in Modern Slavery Laws to promote awareness and provided with resources to escalate concerns if such prohibited activity becomes known to them. In 2017, Moog added training on Modern Slavery Laws to its bi-annual training on its Statement of Business Ethics and gave more in depth Modern Slavery Training to its supply chain personnel. In addition, upon hire, all new Moog Group associates receive this same training as part of our new associate orientation process. All such training reinforces that the consequences for employee violations of our Modern Slavery policy will result in disciplinary action up to, and including, termination. In a further attempt to increase employee awareness, each Moog Group location worldwide is posting employee awareness communications and hotline information for reporting of modern slavery concerns.
3. Audit: we include a contractual provision in our supply agreements requiring our suppliers to comply with Modern Slavery Laws and allowing us to review and audit them periodically for such compliance; we do conduct supplier reviews but do not currently conduct these audits. Our supply chain is also contractually required to make us aware of any forced labour issues that become known regarding it or its own sub-tier suppliers and they are required to flow down such modern slavery provisions to sub-tier suppliers in applicable contracts. Lastly, we have the right to terminate supply contracts if modern slavery issues are found.
4. Certification: under contract, we have the ability to require suppliers to answer a questionnaire disclosing the details of their own modern slavery compliance programme. Whilst we do not currently seek such certification in the regular course of business, we have the contractual ability to require a certification from required suppliers that it has a modern slavery compliance plan in place. We are not currently aware of any issues in our supply chain that would give rise to a violation of our Compliance Plan.
5. Verification / Focus: we monitor regions and markets where modern slavery is most prevalent and pay 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. Having knowledge of this risk allows us to focus our audit and review activities on any electric component suppliers that could be high risk. We are considering the option of utilizing an independent third party to perform unannounced audits on our behalf but do not currently employ an independent third party auditor for such purposes.
6. KPIs (Key Performance Indicators): we will review the following KPIs to measure effectiveness of performance:
a. the number of questionnaires completed by our supply chain;
b. the number of reviews conducted on suppliers delineated as high risk and the results; and
c. through direct communication with suppliers and our vendor approval process, we will gauge the overall understanding of our supply chain as to the importance of this issue and the effectiveness of their own compliance efforts.
7. Violation Reporting Procedures, Whistleblowing & Investigation Support: we have procedures in place for reporting prohibited activities identified in the Modern Slavery Laws and will take appropriate remedial and referral actions if such activity is found. We have an “open door” policy which encourages employees to engage in open and candid discussions regarding our policy, or any violations, with their supervisors, managers, legal, human resources and senior management without reprisal. We also require our employees to report, without fear of retaliation, activity inconsistent with the policy prohibiting modern slavery on its confidential company-specific ethics hotline at 1- 866-519-6330 or email@example.com. All US employees have the right to call the Global Human Trafficking Hotline at 1-844-888-FREE or email firstname.lastname@example.org; and our UK employees have the right to call the same company-specific ethics hotline, or the Modern Slavery Helpline at 08000 121 700 to report suspected violations to government officials outside of the Moog Group. In addition, we will fully cooperate with any government agency conducting an audit or investigation of potential modern slavery violations, including providing timely responses and reasonable and required access to our employees, records and facilities.
For the purposes of this statement the Moog UK subsidiaries are:
· Moog Reading Limited, registered in England & Wales with company number 00586505
· Moog Wolverhampton Limited, registered in England & Wales with company number 07008386
· Tritech International Limited, registered in England & Wales with company number SC085501
· Harmonic Linear Drives Limited, registered in England & Wales with company number 05848861
· Moog Fernau Limited, registered in England & Wales with company number 00989895
· Moog Insensys Limited, registered in England & Wales with company number 02556321
We will continue to review, reassess and further develop our modern slavery approach.
This statement has been approved by the boards of directors of Moog Inc., the parent company of Moog UK and authorised to be signed on its behalf as below.
For any questions related to the foregoing, kindly contact Randy Fahs at email@example.com.
John Scannell, Chairman & CEO Moog Inc.
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