Supply Chain Transparency Disclosure

At The Kinetic Group we insist on ethical behavior and respect for human rights and require that our suppliers do the same. This Disclosure provides information about the efforts of The Kinetic Group and its subsidiaries as required by the California Transparency in Supply Chains Act.

RISK ASSESSMENT

Our Supplier Social Responsibility Code outlines and reinforces our commitment to ethical behavior at every level, and as a condition of doing business with us, our suppliers are required to represent and warrant their compliance with all applicable laws, including laws respecting human trafficking and slavery. We do not utilize a third party to evaluate the risk of human trafficking and slavery in our supply chain.

SUPPLIER AUDITS

The Kinetic Group currently does not perform formal audits on suppliers, but we will continuously evaluate their benefits as we assess and monitor the risks of human trafficking in our supply chain.

CERTIFICATION

The Kinetic Group includes a clause in its contractual Terms and Conditions of Purchase that requires our suppliers to warrant their compliance to human trafficking standards. As a condition of doing business with us, our suppliers warrant that “all Goods and Services (including materials incorporated into the Goods) . . . are manufactured in compliance with the laws regarding human trafficking and slavery in the country or counties in which they are made.”

ACCOUNTABILITY STANDARDS

We maintain a 24-hour ethics hotline where employees may anonymously report violations of the law or our Social Responsibility Code. Any employee or supplier found to be in violation of our standards will be subject to remedial action, up to and including termination.

TRAINING

The Kinetic Group has partnered with a leading corporate responsibility consultancy and is providing its supply chain staff, including supply chain management, with training on this subject. The annual course provides awareness on human trafficking and slavery, information on how to identify human trafficking and slavery risks in a supply chain, and prevention and mitigation efforts when human trafficking is suspected.

The Kinetic Group is committed to doing its part to help mitigate the risks of human trafficking in its supply chain.