California Transparency in Supply Chains Act

The following statement outlines Edmund Optics commitment to ensuring that slavery and human trafficking are not tolerated in our business, or at any point within our supply chain. This Statement covers the calendar year ending 31 December 2023.

Edmund Optics does not tolerate any form of human trafficking, exploitative practices or any other form of forced working, including:

• Slavery, debt bondage, servitude or any other form of coercive practice;
• the use of any form of forced/compulsory labour or exploitative practices including the confiscation of passports, travel documents or other official documentation;
• the trafficking of persons under a false or manipulated pretence.

Edmund Optics continues to maintain adherence to the UK Modern Slavery Act 2015, the California Supply Chain Transparency Act, as well as any other applicable anti-slavery laws.

Summary

Edmund Optics recognizes the important role we play in protecting the rights of our employees as well as those people working within our supply chains throughout the world. Embedded in our culture is a profound commitment to “do the right thing” for our employees, customers, and other stakeholders.

We continue to work to communicate to our global supplier base, that our supply chains should ensure their workforce are treated fairly, with respect to human rights, and that they are also not exposed to any unsafe working practices. This commitment is primarily communicated to our suppliers via the EO Supplier Code of Conduct, which sets out our expectations of the supplier’s operations, as well as general business conduct.

Policies

To reinforce our Company values, Edmund Optics provides a number of resources to our employees and suppliers to help them understand, identify and report any concerns. This includes our Code of Conduct and our Supplier Code of Conduct, both of which expressly prohibit forced labor and human trafficking, our employee handbook, as well as other information made available internally as well as via our public website. Some of the elements covered within these sources are:

• Supplier Code of Conduct:
  • Human Rights Policy
  • Antitrust Compliance
  • Conflict of Interest Policy
  • Anti-Corruption Policy
• Employee Handbook:
  • Equal Opportunities
  • Diversity, Equity and Inclusion
  • Workplace Conduct, including non-harassment and anti-bullying
• Information Security Policies and website Privacy Policy

Edmund Optics maintains standards and procedures designed to ensure that employees comply with applicable policies. We have established the EO Ethics Alert Hotline for reporting possible ethics violations to ensure that any employee or third party wishing to submit a report can do so anonymously and without fear of retribution. Reports of potential violations are investigated, and violations are addressed.

Supply Chain

Edmund Optics sources products from around the world, utilising our local presence to interface more directly with our suppliers. As part of our new supplier process, we provide suppliers with a copy of our Supplier Code of Conduct. Topics consistent with our core values, such as modern slavery and human trafficking are included within this document. New suppliers are required to agree to the terms within our supplier code of conduct, which includes a prohibition on the use of forced labor and human trafficking, as well as to make best efforts to ensure these requirements are met by their suppliers. Edmund Optics has also contacted all of our existing suppliers to request they also agree to the commitments within our Supplier Code of conduct. Furthermore, we have made available German, Chinese and Japanese translations in order to better communicate our requirements to our suppliers.

Edmund Optics Supply chain teams are responsible for leading our supplier due diligence process and other key supply chain initiatives worldwide, including ensuring that:

• Our suppliers agree to comply with our Supplier Code (or demonstrate that their own Code requirements are at least equivalent to ours), implement ethical business practices, maintain safe and healthy working conditions, and strive for continuous improvement with respect to human rights-related issues;
• Edmund Optics prioritises suppliers that align with our goals on responsible sourcing and support our business goals; and
• Edmund Optics achieves greater supplier diversity ensuring that our supply chains are more resistant to changes in the global environment and less subject to disruption due to local events.

While Edmund Optics occasionally conducts audits of its third parties, it does not currently conduct independent, unannounced audits of suppliers to confirm their compliance with anti-slavery and human trafficking laws.

Export Controls

Edmund Optics complies with applicable U.S. and international sanctions, embargos and export regulations. Neither Edmund Optics nor its directors, officers, employees, or suppliers are listed on any international sanctions lists including; the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) or Specially Designated Nationals (SDN) List. Edmund Optics maintains and reviews a list of countries, some of which are subject to a restrictions on the level of sales/service provided. These lists are reviewed on a frequent basis to ensure they remain up to date and include U.S. embargoed country, such as Cuba, Iran, North Korea, and Syria, as well as other countries who may be subject to various issues including increased fraud, civil unrest or increased international sanctions. Factors such as, internal oppression and slavery are also considered when determining which countries should be subject to some level of sales restriction.

Employment and Working Practices

Edmund Optics maintains robust recruiting processes that meet or exceed local laws, including right to work, document checks, employment contracts for all employees, and checks to ensure that all employees are above the minimum working age. Our pay and benefits packages are reviewed annually, and are linked to appropriate benchmarks.

Throughout the pandemic, Edmund Optics has prioritized the health and safety of its workforce. This includes taking steps to ensure employees are equipped to work productively from home, imposing business travel restrictions (and an approval process) and implementing a thoughtful and voluntary approach to returning to the office for fully vaccinated employees, in certain areas, as well as providing training and other tools to all levels within the Company.

Training

Edmund Optics has a robust compliance training program for all employees. This program provides employees with training on various topics, including relevant Codes of conduct, data privacy/security, and harassment/discrimination training. New employees are also required to review and acknowledge a range of applicable key policies as part of their onboarding process.