Policy Against Human Trafficking and Slavery for Suppliers

I. Purpose

Gatan, Inc. is committed to a work environment that is free from human trafficking, forced labor and unlawful child labor (“human trafficking and slavery”). We strongly believe that we are responsible for promoting ethical and lawful employment practices. These practices are also required to be followed by our suppliers, subcontractors or business partners (collectively referred to as “Suppliers”) worldwide. This policy also complies with the California Transparency in Supply Chains Act as well as Federal Acquisition Regulations (“FAR”) for Strengthening Protections Against Trafficking in Persons in Federal Contracts, and Title XVII of the National Defense Authorization Act of 2013, entitled “Ending Trafficking in Government Contracting”.

II. Scope

This policy covers all employees of Gatan, Inc. and all of its subsidiaries (collectively referred to as “Gatan, Inc.”), and all of its Suppliers. In the event anything in this policy may conflict with local law, local law will control the interpretation and application of this policy. 

III. Definitions

Human Trafficking: the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, or fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. 

Forced Labor: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty. 

Harmful Child Labor: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development. 

IV. Rationale

Gatan, Inc. will not tolerate the use of unlawful child labor or forced labor in the manufacture of products it sells and will not accept products or services from Suppliers that employ or utilize child labor or forced labor in any manner. Human trafficking and slavery are crimes under state, federal and international law. This Policy is to define how Gatan, Inc. will make efforts to eradicate human trafficking and slavery from not only within its organization but also from our supply chains. 

V. Requirements

Gatan, Inc. employees or Suppliers shall:

  1. Not use forced or compulsory labor, i.e., any work or service that a worker performs involuntarily, under threat of penalty.
  2. Not use any third party recruitment companies or agencies that charge recruitment fees to perspective employees or otherwise act contrary to this policy or applicable law. 
  3. If applicable, agree to provide return transportation to any worker who is displaced or relocated from his/her origin country as part of employment. 
  4. If applicable, agree to comply with all local housing requirement and standards if housing is offered to employees. 
  5. Ensure that the overall terms of employment are voluntary.
  6. Comply with the minimum age requirements prescribed by applicable laws unless a specific contract contains stricter age requirements.
  7. Compensate its workers with wages and benefits that meet or exceed the legally required minimums and overtime requirements of the worker’s jurisdiction.
  8. Abide by applicable law concerning the maximum hours of daily labor.

VI. Certification

Upon request, Suppliers will certify that materials incorporated into the products they provide comply with the laws regarding human trafficking and slavery of the country or countries in which they are doing business.

VII. Audits

Suppliers must be able to demonstrate compliance with this Policy at the request and satisfaction of Gatan, Inc. 

VIII. Violation Reporting

Any employee or Supplier who has knowledge or information regarding a possible violation is encouraged to either report the violation to the Human Resources department or report the information anonymously through the Roper Technologies, Inc. ethics hotline: 1-888-227-3565.

IX. Consequences

Suppliers who engage in human trafficking and slavery will have their supply agreements terminated. 

Any employee of Gatan, Inc. who violates this policy or related applicable laws is subject to disciplinary action up to and including termination.