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 22 May 2024.

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.