1. Overview
Snap One, LLC (“Snap One”) does not tolerate human trafficking or slavery in its operations or its suppliers’ operations. Snap One encourages all its procurement employees to be vigilant regarding human trafficking and slavery in Snap One’s supply chain and to report any suspected human trafficking or slavery to the Office of Legal Compliance at Legal Compliance team at ABC@snapone.com. Snap One will not retaliate against employees who report suspected human trafficking or slavery in the Snap One supply chain.
The following disclosures are made pursuant to the California Transparency in Supply Chains Act of 2010 (Section 1714.43 of the California Civil Code),United Kingdom Modern Slavery Act of 2015 (Section 54), and Australian Modern Slavery Act of 2018 (collectively referred to in this disclosure as the “Acts”).
2. To what extent, if any, does Snap One:
(2.1) Engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery?
Almost all of our products are sourced from third-party suppliers, and our employees conduct periodic site visits and quarterly reviews of certain of our suppliers, which include reviews of working conditions, employee turnover, and other metrics designed to ensure that our largest partners are providing fair working conditions for their employees. We do not at this time engage in a formal independent verification of their product supply chains with respect to human trafficking and slavery, but depending on the results of our reviews, we do conduct additional investigations if the results raise concern that human trafficking is being used anywhere in our supply chain.
(2.2) Conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains?
As mentioned above, our employees conduct periodic site visits and reviews of certain of our suppliers, but we do not formally audit suppliers for compliance with our company’s standards for human trafficking and slavery. With that said, if there is any reason to suspect that one of our suppliers is not complying with human trafficking and slavery standards, then we address the matter with the supplier promptly.
(2.3) Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business?
We contractually require suppliers to be and remain in compliance with all applicable laws and regulations. In addition, we maintain a Partner Code of Conduct that explicitly prohibits human trafficking and requires that our partners take all reasonable steps to ensure human trafficking is not taking place in their business or supply chains. Failure to comply with this Partner Code of Conduct or applicable laws regarding slavery and human trafficking could disqualify a company from continuing to serve as our supplier.
(2.4) Maintain internal accountability standards and procedures for employees or contractors failing tomeet company standards regarding slavery and trafficking?
Our employees are required to acknowledge and adhere to its Standards for Professional Conduct which requires that employees abide by the applicable laws and regulations in each country in which Snap One does business, including those related to slavery and human trafficking. Employees are also required to report any suspected violations.
(2.5) Provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products?
Snap One engages in a thorough hiring and training process for all employees but does not currently provide specific training on human trafficking and slavery. Snap One’s Legal Department is working to develop and implement specialized training for members of its supply chain workforce to recognize and mitigate human trafficking and slavery risks in the supply chain.
3. Contact Snap One
If you have any questions or concerns regarding a Snap One product or this Disclosure, please contact us at any of the following.
Via e-mail: reporting@SnapOne.com
Via mail:
Snap One, LLC
1355 W Innovation Way STE 125,
Lehi, UT 84043
Attn: Office of the Chief Legal Officer
Sincerely,
JD Ellis
Chief Legal Officer
Phone
(866) 424-4489
