Statement on the California transparency in supply chains Act (2010) and the UK modern slavery Act of 2015 (Section 54)
Universal Electronics Inc. (“UEI”, “we or our” and the “Company”) is committed to fair labor practices and human rights in its business and supply chain. Our actions in this area are as follows:
- Verification of our Business and Supply Chain.
We commit resources to periodically evaluate our business and supply chain. Our practice is to monitor, detect, and prevent instances of human trafficking and slavery in our business and supply chain. We employ processes and tools for due diligence on our employees and our suppliers at all tiers. This includes periodic audits of certain of our suppliers that we perform or have performed on our behalf by third-party firms and the annual affirmation we receive from our suppliers that they understand and agree to adhere to our Global Supplier Code of Conduct and Fair Competition Policy. In addition, we are in the beginning stages of utilizing a risk-based comprehensive questionnaire to survey the practices of participants in our supply chain and to ensure they are compliant with applicable laws, including those related to human rights. In addition, our contracts with suppliers reserve the right to audit all suppliers’ records and facilities to assure compliance with applicable laws.
We require, through our contracts and through an annual affirmation of an understanding of and adherence to our Global Supplier Code of Conduct and Fair Competition Policy, our suppliers to certify, to the best of their knowledge and belief, that they do not engage in or support human trafficking, slavery or servitude, or use any indentured bonded, prison, or forced labor.
Since the Company was founded, UEI has prided itself on being a fair and equal opportunity employer, providing our employees with a work environment free of discrimination and harassment. Under no circumstances will we ever tolerate forced labor in any form or at any of our locations and we hold each of our employees to these standards. Further, our business practices have been governed by integrity, honesty, fair-dealing and full compliance with all applicable laws. We require our employees to annually review the Company’s Code of Conduct and sign a Code of Conduct Acknowledgment Form. We also provide periodic training to our employees and will continue to do so, particularly including human rights training during 2022.
We have implemented a company-wide training and awareness program on human rights and will further augment this training with segments pertaining to the prohibition against human trafficking and forced labor. Our program, in which we are in the beginning stages of implementing, addresses the definitions of human trafficking and forced labor, how to minimize potential risks, types of prohibited activities, how to report suspected violations, and the importance of these issues to the Company. Included in this training will be detailed training to employees and management with direct responsibility for supply chain management. In keeping with our ongoing commitment to continuous improvement, we will regularly evaluate our training and awareness programs in order to assess needs and to address changes in applicable laws and circumstances.