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McILHENNY COMPANY DISCLOSURE STATEMENT AND COMPLIANCE PLAN ON OPPOSING HUMAN TRAFFICKING AND FORCED LABOR BY CONTRACTORS AND VENDORS AND IN THE SUPPLY CHAIN

McIlhenny Company is committed to conducting its business according to the highest ethical standards and in compliance with all applicable laws. All employees are expected to honor our Code of Conduct and commitment to integrity and ethical behavior in all matters relating to our business, at all times, everywhere in the world. We also expect our contractors, vendors, and other business partners to share our commitment to ethical and responsible business practices.

In keeping with this vital mission, we are opposed to human trafficking and forced labor in any form, on any level, under any circumstances, anywhere in the world, including in our direct product supply chains and in all our contractor and vendor relationships. The following are steps we take to guard against forced labor and human trafficking in our direct product supply chains and in all our contractor and vendor relationships.

Supplier Certifications

  • All contractors and vendors, including suppliers in our direct product supply chains, are asked to certify that they do not participate in, encourage, aid, or foster forced labor or human trafficking in any manner and that they comply with all applicable laws regarding human trafficking and forced labor. Our direct product supply chains include suppliers of products we sell or of commodities we use in the products we manufacture.

Internal Accountability and Training

  • McIlhenny employees, including all employees responsible for direct product supply chain management or procurement, are instructed through our Code of Conduct to notify their direct supervisors or the Human Resources Department or to call the company’s confidential anonymous hotline if they witness or receive credible information regarding a violation of company policies and standards on forced labor and human trafficking in our direct product supply chains or by any contractor or vendor.

Supplier Audits

  • At present, the Company lacks the resources to conduct independent, unannounced audits of compliance by suppliers, contractors, and vendors with our standards on human trafficking and forced labor. Thus we rely on compliance with our Code of Conduct and certifications by our suppliers, contractors, and vendors to guard against human trafficking and forced labor in our direct product supply chains and contractor and vendor relationships.
  • We will investigate any issue of human trafficking or forced labor by any supplier in our direct product supply chains or any other contractor or vendor that comes to our attention and take appropriate corrective action, including reporting violations to government authorities, to insure that our direct product supply chains and contractor or vendor relationships are not tainted by human trafficking or forced labor.

This disclosure statement and compliance plan is intended to comply with Executive Order 13627 entitled, “Strengthening Protections Against Trafficking in Persons in Federal Contracts,” the California Transparency in Supply Chains Act, and other similar laws.