MODERN SLAVERY STATEMENT

MODERN SLAVERY STATEMENT

Financial year ending March 31st, 2021

INTRODUCTION

This statement is made pursuant to Section 54(6) of the Modern Slavery Act 2015 and
sets out Héroux-Devtek Inc. and its subsidiaries’ (collectively, “Héroux-Devtek”)
commitment to address issues of slavery and human trafficking within its supply chains
and in any part of its business.

OUR COMPANY

Héroux-Devtek specializes in the design, development, manufacture, repair and
overhaul of landing gear and hydraulic systems and components for the Aerospace
market. Héroux-Devtek is the third largest landing gear company worldwide, supplying
both the commercial and military sectors with new landing gear and hydraulic systems
and components, as well as aftermarket products and services. It is Héroux-Devtek’s
policy and objective to maintain the highest standards of ethical business conduct.
Héroux-Devtek’s directors, officers and employees are committed to sustain a culture
where ethical conduct is recognized and exemplified. We have zero tolerance to slavery
and human trafficking in any part of our organisation or supply chains.

OUR SUPPLY CHAINS AND OUR POLICIES

Our supply chains are critical to our success and, in order to provide superior products
and services in a responsible manner, we require all of our suppliers and contractors to
comply with our values and ethics.

To ensure that we maintain the highest standards of ethical business conduct and in
order to avoid any integrity issue, Héroux-Devtek has implemented various internal
policies for our employees and supply chains, including:

– Employee Code of Conduct and Supplier Code of Conduct,
– Whistleblower Policy, and
– Contractual provisions in purchase documents.

Furthermore, Héroux-Devtek conducts due diligence on its supply chains through
various methods, including verification of government debarments and denied parties
lists. We require as a condition of contract that all suppliers and contractors agree to
comply with all laws and regulations applicable to the operation of their business and
their relationship with Héroux-Devtek.

Héroux-Devtek will reconsider its business relationship with any supplier or contractor
that does not meet the expectations set out in the Supplier Code of Conduct.

AUDITS AND TRAINING

The compliance program Héroux-Devtek has developed include: (i) periodical supply
chains audits, requiring suppliers and contractors to certify that they do not engage in
human trafficking or slavery activities, and (ii) employees training program to make sure
relevant members of the organisation understand how anti-slavery regulations and
corporate policies apply in the context of their role.

This statement is scheduled for approval by the board of directors of Héroux-Devtek Inc.
on May 19, 2021.

 

Jean-Philippe Sanche
Director Legal Affairs
Héroux-Devtek Inc.

 

* These corporate governance documents contain provisions consistent with section 52.222-50 of the U.S. Federal Acquisition Regulation (FAR) related to combating trafficking in persons and will be updated to add specific references to the Modern Slavery Act 2015.