Modern Slavery Statement

Policy

Sierron is committed to maintaining a workforce and supply chain free of human trafficking and all forms of forced or unlawful labor. We have a zero-tolerance policy toward modern slavery, which encompasses human trafficking, servitude, and forced labor. This policy is consistent with our core values and supports our compliance with the Modern Slavery Act 2015 and all applicable U.S. Government regulations regarding slavery, forced labor, and trafficking in persons. In compliance with these laws, Sierron employees are trained and annually acknowledge that they will uphold our Code of Ethics and Business Conduct.

Supplier Due Diligence

In compliance with Sierron’s Policy Against Trafficking in Persons and Slavery and, by extension, the Modern Slavery Act 2015, Corporate Quality Assurance representatives perform independent reviews and audits to ensure procurement-process compliance with U.S. federal regulations. Our U.S. federal vendors annually certify their compliance with the Supplier Representations and Certifications document, which includes compliance with laws on human trafficking and slavery in the countries where they do business. The Combating Trafficking in Persons clauses in U.S. Federal Acquisition Regulation 52.222-50 are incorporated into Sierron subcontracts, as required, when doing business on behalf of U.S. federal customers.

Sierron has updated its Purchase Order Standard Terms and Conditions and agreement templates to incorporate anti-human-trafficking language for all subcontracts awarded in support of U.S. federal and state work.

Reporting

Sierron has established a formal policy that enables and encourages all employees to report any concerns, violations, or potential violations of this policy — without fear of retaliation — to their supervisor, another member of management, Sierron Security, or Human Resources.

Sierron follows the investigative procedures found in the Employee Handbook on Sierron’s intranet. Once a complaint is received, Sierron conducts a prompt and thorough investigation, which may include interviews with involved employees and others with relevant knowledge. Once the investigation is complete, a determination is made regarding the validity of the allegations, and prompt remedial action is taken if a violation is found.

Violations by employees will result in disciplinary action, up to and including termination of employment. Sierron may also terminate its commercial relationship with suppliers, contractors, or other business partners who breach this policy or are found to have been involved in slavery or human trafficking.

Training & Awareness

All employees submit annual certifications stating that they understand, will comply with, and have complied with Sierron’s Policy Against Trafficking in Persons and Slavery. Copies of all signed certifications are maintained by the Human Resources Department.