California Transparency in Supply Chain Act of 2010

In accordance with the California Transparency in Supply Chain Act of 2010, Kontron is proud of its uncompromising integrity and its efforts to ensure the highest level of lawful and ethical conduct from its employees, business partners, and suppliers. These efforts include adherence to a strict Code of Conduct which, among other things, confirms that Kontron does not under any circumstances tolerate unethical behavior or white-collar crime in any form, including human trafficking or slavery. Moreover, Kontron trains its staff to be sensitive to these issues, such that should any of them observe such illicit activity, they must turn to appropriate supervisors or contact business partners in the affected region, with queries and doubts concerning such matters. This Code of Conduct further requires all staff who are working or conducting business abroad to comply with all local laws, regulations, and social norms.

Kontron’s Code of Conduct requires particular scrutiny before a major business transaction with new suppliers, and directs its staff members to inform themselves sufficiently about contractual partners' business environment, the contractual party itself, and the purpose of the transaction in which the contractual party intends to enter. Because the scourges of human trafficking and slavery are often accompanied by indications of money-laundering and/or unusually large cash payments, Kontron likewise strives to ensure that all of its suppliers’ payments are reflected on a corresponding invoice, that payments are not made by a third party but by the actual contractual supplier unless specifically arranged and agreed to, and that normal and reasonable charges, accounting and bookkeeping are followed.

Kontron’s staff members are guided to immediately inform managers or the compliance officer in cases of doubt, or where there is a suspicion of irregularities. Staff members are obliged to provide information if they suspect an instance of any criminal offence.

In addition to its Code of Conduct Kontron’s standard “Terms and Conditions” expressly prohibits its suppliers from engaging in human trafficking or slavery with respect to the products they provide to Kontron. Kontron also makes intermittent inquiries to ensure compliance with its contractual requirements.

Kontron also has a well established and fully implemented an Equal Employment Opportunity (EEO) Policy that prohibits discriminatory treatment of any Kontron employees. Additionally, subcontractors, vendors, and suppliers are notified in writing of our EEO policy, which specifically includes a prohibition against human trafficking and slavery. All subcontractors, vendors and suppliers are requested to practice the appropriate action on their part in their operations and in their relationship with our company, consistent with this EEO policy.

In each of these ways Kontron (1) seeks to ensure that its supply chains evaluate and address the risks of human trafficking and slavery; (2) periodically conducts inquiries regarding its suppliers to evaluate compliance regarding Kontron’s Code of Conduct, Terms and Conditions, and EEO policies; (3) requires that its suppliers comply with applicable law, including those regarding slavery and human trafficking; (4) maintains internal standards and procedures for those company contractors who fail to adhere to Kontron’s policies regarding human trafficking and slavery; and (5) provides training to the managerial and other Kontron employees with respect to reducing the risk of human trafficking and slavery in their supply chains. Kontron engages in these functions on its own behalf, without the use of a third party.


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