California Supply Chains Act Disclosure

Disclosure under the California Transparency in Supply Chains Act

Introduction

Unifrax is an international company that does business around the world and prides itself on being a good corporate citizen. Its success as a corporate citizen is built on a commitment by every employee to uphold the highest ethical standards of professional conduct on the job. In the view of Unifrax’s management, the best way to sustain an ethical culture is for each employee to act with integrity every day—doing the right thing when it comes to an employee’s own behavior, encouraging others to do likewise, being aware of what is going on around us and being willing to speak up when one sees or suspects activity that is contrary to Unifrax’s policies or practices. Unifrax’s commitment to ethical conduct, which is codified in its Code of Business Ethics, extends to its supplier network by building and maintaining long-standing business relationships.

 Verification

Unifrax believes that “knowing its supplier” is a cornerstone of its supply chain functioning in an ethical and law-abiding manner. While Unifrax does not currently take any action to specifically evaluate the risks of slavery and human trafficking by its suppliers, it does see relationship-building as a key to avoid doing business with suppliers engaged in unethical and illegal conduct and as a foundation to any future supplier evaluation or policy regarding slavery and human trafficking. To the extent Unifrax has any concerns regarding the business practices of a supplier, it will investigate. Unifrax has not engaged a third party to conduct any verification of its suppliers’ compliance with any ethical standards.

Audits

Unifrax does not currently conduct audits of suppliers specifically targeted at slavery and human trafficking. However, Unifrax is consistently reviewing, albeit not in a formal audit, the performance of its suppliers under their respective contracts, which in many cases affirmatively require that suppliers comply with applicable law. These reviews can include facility tours, interviews of management personnel of a supplier and other measures that might reveal the existence of non-compliance with any applicable law by a supplier.

Certification

Unifrax does not require a certification from its direct suppliers that materials incorporated into Unifrax’s products comply with laws addressing slavery and human trafficking.  However, Unifrax in many cases contractually requires that suppliers comply with applicable law in performing their obligations to Unifrax. A supplier’s contractual obligation to comply with applicable law would cover any applicable law relating to slavery and human trafficking.

Internal Accountability

All employees and suppliers of Unifrax are required to comply with, and will be held accountable if for any reason they do not comply with, all policies and practices of Unifrax, or any applicable law, including any policies, practices and law relating to slavery and human trafficking. Unifrax considers ethical and law-abiding conduct as a condition to an employee’s continued employment with, and a supplier’s continuing to be part of the supply chain of, Unifrax. Unifrax does not, however, currently have a formal internal procedure for determining whether employees or suppliers comply with its standards regarding slavery and human trafficking. Unifrax does, on the other hand, have a Business Code of Ethics and has taken other steps to hold employees and suppliers accountable for failing to meet its ethical standards and legal requirements.

In 2013, Unifrax added an internal whistleblower hotline, called the “Integrity Line.”  The “Integrity Line” enables Unifrax employees to anonymously report any illegal or unethical conduct observed on the job, including any such conduct relating to slavery and human trafficking.  To support this initiative and raise awareness of the “Integrity Line,” Unifrax prominently displays wall posters at all locations, distributes cards and pamphlets detailing the hotline, and updated its Business Code of Ethics to include information (including a phone number) on the “Integrity Line.”  At all non-English speaking sites, the information on the “Integrity Line” has been translated into the local language. Whether through the “Integrity Line” or other proactive measures, Unifrax supports its employees who desire to assist it in achieving high ethical standards and legal compliance.

Penalties for non-compliance with Unifrax’s ethical standards and legal requirements will depend on the severity of the non-compliance, whether the non-compliant employee or supplier is a repeat offender, and other relevant criteria. Non-compliant employees and suppliers may be given an opportunity to adopt corrective measures. Likewise, any non-compliance with ethical standards and legal requirements will usually result in a review of relevant policies and practices of Unifrax to determine if changes would be appropriate to reduce future non-compliance.

Training

Unifrax currently runs training programs from time to time designed to assist its employees perform their responsibilities better and to communicate corporate policies and practices.  Employees directly involved in Unifrax’s supply chain management would be included in these programs, and an employee’s obligation to comply with applicable law and ethical standards is occasionally covered by these programs. While the importance of legal and ethical conduct is at times covered in these programs, Unifrax does not currently provide training that specifically focuses on slavery and human trafficking.

Conclusion

Unifrax is steadfast in its commitment to doing business in an ethical and legal manner. Unifrax Management constantly monitors its business activities, making adjustments that are appropriate in light of a rapidly changing world and to reasonably ensure that its business operations meet the high standards set by Unifrax. Management’s commitment includes taking action (such as changes to its policies and practices) whenever its monitoring reveals that these standards are not being met by its employees or suppliers.

Questions

The purpose of the California Transparency in Supply Chains Acts is to “educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains.” If any interested party has a question regarding Unifrax’s efforts to assist in achieving this goal, please contact Unifrax as follows:

Vice President of Human Resources

716-768-6500

Unifrax Corporate Headquarters

600 Riverwalk Parkway

Tonawanda, NY 14150