INTRODUCTION

This statement is made pursuant to Section 54 of the United Kingdom (UK) Modern Slavery Act 2015 (the “Act”) which requires companies carrying on business in the U.K. to publish a statement describing steps taken to ensure modern forms of slavery and human trafficking are not taking place in the company’s business operations and supply chains. This statement sets out of the steps taken by ELECTRO DEFENSE for the current fiscal year to ensure that slavery, servitude, forced or compulsory labor and human trafficking (collectively, “Modern Slavery”) is not taking place in any part of its business or in its supply chains.

BUSINESS

ELECTRO DEFENSE manufactures and distributes electrostatic sprayer products to clients in the United Kingdom.

POLICIES AND PRACTICES

ELECTRO DEFENSE’s commitment is to act with integrity in all its business dealings and to promote ethical conduct to enhance compliance with applicable law and to provide guidance with respect to business conduct. ELECTRO DEFENSE has several policies that are relevant to this commitment, which set out what ELECTRO DEFENSE expects from its employees, internal business, and its external suppliers.

Key policies are:

• ELECTRO DEFENSE’s Suppliers’ Code of Conduct. The Supplier Code of Conduct outlines our expectations for supplier conduct regarding labor and human rights in addition to health and safety, environmental protection, ethics, and management practices.

• ELECTRO DEFENSE expects its suppliers to share its commitments and to act in full compliance with all applicable laws, including all national, local and international laws relating to the management of their businesses.

• ELECTRO DEFENSE requires its suppliers to seek approval before subcontracting any part of their supply chain process and ELECTRO DEFENSE’s approval is subject to acceptance by the subcontractor of the Suppliers’ Code of Conduct and such other conditions that ELECTRO DEFENSE determines.
• ELECTRO DEFENSE Code of Conduct

• Our anti-Modern Slavery policy reflects our commitment to act ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

• The ELECTRO DEFENSE Code of Conduct applies to all employees and has been disseminated to all employees. It is also available on the ELECTRO DEFENSE intranet website.

• ELECTRO DEFENSE expects its employees and suppliers to engage in and promote honest and ethical conduct, comply with all applicable laws, rules and regulations in their own area and act responsibly, with due care, competence and diligence when dealing with colleagues, customers, suppliers, agents and intermediaries.

• The ELECTRO DEFENSE Code of Conduct reiterates the LVMH Code of Conduct and commitment to act with the highest standards of integrity, respect and engagement in our behaviors and in the way that we conduct business every day, everywhere.

• ELECTRO DEFENSE aims to inform all of its commercial partners about the principles and expectations covered in our Employee and Supplier Codes of Conduct; in particular, respect and adherence to the company moral and ethical values in the management of the company concerning human rights, working conditions, and environmental issues

SUPPLIER AND CONTRACTOR DUE DILIGENCE

ELECTRO DEFENSE carefully reviews its suppliers.

ELECTRO DEFENSE reserves the right to check adherence of its suppliers and contractors to the principles set out in the Suppliers’ Code of Conduct and to conduct compliance audits at any time without notice. Upon reasonable request, ELECTRO DEFENSE suppliers and contractors shall supply the necessary information and grant access to ELECTRO DEFENSE representatives to verify compliance with the requirements of the Suppliers’ Code of Conduct. Suppliers and contractors shall further keep proper records to provide compliance with this Code and provide access to complete, original and accurate files to ELECTRO DEFENSE representatives.

Upon reasonable request, ELECTRO DEFENSE suppliers and contractors must improve and correct any deficiency discovered during any such audits. ELECTRO DEFENSE reserves the right to terminate supplier relationships where a supplier is in breach of our Supplier Code of Conduct.

ELECTRO DEFENSE shall use its reasonable endeavors to ensure that all ELECTRO DEFENSE supplier and contractor template contracts contain clauses requiring ELECTRO DEFENSE’s suppliers and contractors to adopt similar anti-modern slavery standards and practices.