Modern Slavery Policy

Purpose

Element U.S. Space & Defense and the United States Government prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.”

We are committed to maintaining a work environment that is free from human trafficking and slavery, which for purposes of this policy, includes forced labor and unlawful child labor. We will not tolerate or condone human trafficking or slavery in any part of our global organization. The policy is consistent with our Code of Conduct and Business Ethics and expresses our firm commitment to protect and advance human dignity and human rights in our business practices.

We expect our employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners, and others through whom we conduct business to avoid complicity in any practice that constitutes trafficking in persons or slavery.

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Scope

This policy applies to all personnel employed by or engaged to provide services to us, including, but not limited to, employees, officers, and temporary employees of the Company, and independent contractors (for ease of reference throughout this policy, “employees”).

Every employee is responsible for reading, understanding, and complying with this policy. Managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this policy and complete any certification or training required of them. If you have any questions or concerns relating to this policy, consult Human Resources through your Human Resources Business Partner or at [email protected].

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Summary of US Government Policy of Prohibiting Trafficking in Persons

The Company complies with all applicable human trafficking and slavery laws, including global human rights laws prohibiting human trafficking and slavery, and we require our business partners to do the same. This includes, but is not limited to, the following:

Engaging in any form of trafficking of persons, including sex trafficking
Using force, fraud, or coercion for the purpose of subjecting a person to involuntary servitude, peonage, debt bondage, or slavery
Procuring commercial sex acts
Using forced labor in the performance of any work
Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority
Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, basic information; or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing, and associated costs (if provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work
Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place
Charging applicants recruitment fees
If required by law or contract, failing to provide return transportation, or failing to pay for the cost of return transportation upon the end of employment
If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards
If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing with legally required information and in a language the employee understands
Engaging in child labor, forced, bonded, or indentured labor, involuntary prison labor, slavery, trafficking of persons, physical punishment, or inhumane work conditions
Failing to pay minimum wage

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Raising Concerns

You must report any conduct that you believe to be a violation of this policy to Human Resources immediately. Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

If you prefer, reports may also be made through the NTS Ethics Hotline at 888.416.1307 or via the internet at the following website: https://secure.ethicspoint.com, which allows anonymous reporting as permitted by applicable law.

We will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

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Accountability

The Company will promptly investigate any suspected breach of this policy or applicable law.

Company representatives found in violation of the law or this policy, or who fail to cooperate with an investigation, will be subject discipline up to and including termination. In addition, any noncompliance by our business partners may result in termination of our business relationship.

Violation of the U.S. Government’s policy against human trafficking may also result in criminal prosecution of responsible individuals.

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Resources

Ethics Hotline

(888) 416-1307

https://secure.ethicspoint.com

Human Resources

[email protected]

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