California Supply Chain Act

Flow, a Shape Technologies Group’s company, is committed to fair labor practices within our direct supply chain ensuring that its suppliers do not use slave labor or engage in human trafficking. Flow engages in verification by evaluating the risk of human trafficking and slavery in Flow’s direct (first tier) supply chain as described below:

• Flow selects suppliers after detailed reviews of their operations.
• Flow conducts periodic on-site supplier visits, announced and unannounced, for various reasons, including verification and auditing of contract compliance.
• Flow employees, not third parties, generally conduct such visits.
• The visits are typically not focused solely on slavery or human trafficking.
• Evidence of labor violations, if any, are documented and reported to Flow for review and action.
• If such evidence is discovered, Flow personnel will report those findings to their management and/or through other Flow channels such as the Ethics Line  

Flow does not require its suppliers to certify that the materials incorporated into the products they deliver to Flow comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. However, to ensure that our contractors and suppliers respect and enforce our standards, Flow includes a Compliance with Laws and Rules clause in its contracts with its direct suppliers requiring supplier compliance with applicable statutes and government rules, regulations, and orders, which necessarily include compliance with applicable laws or regulations pertaining to human rights and eradicating human trafficking and slavery.
 
Flow has Global Guiding Principles ("Principles") requiring employees to comply with all applicable laws, rules, and regulations. Currently, we do not provide employees or contractors with training on human trafficking and slavery. All employees receive training on the Principles. Any employee determined to have violated the Principles will be subject to discipline, up to and including termination.