BELCAN, HUMAN RIGHTS & MODERN SLAVERY POLICY

Human Rights Policy

People First is a core principle at Belcan. Human rights reverence is fundamental in our business practice. Belcan is based on trust, integrity, performance, and pride. We are committed to earning our employees and customers trust with the highest standards of integrity, accountability, and respect. Our commitment to human rights is reflected in our policies regarding Human Rights, Diversity and Inclusion, Safety in the Workplace, Child and Forced Labor Policy, Human Trafficking and Slavery Policy, Community Engagement, Wellness Program, Employee Assistance Program, and Ombudsman.

Child and Forced Labor Policy

Belcan is committed to a work environment that is free from human trafficking and slavery, including forced labor and unlawful child labor. Belcan and its subsidiaries does not employ any person below the age of eighteen years old in the workplace, unless in conjunction with an educational training program and/or in compliance with local law. Belcan prohibits and will not tolerate the use of child labor and forced or compulsory labor in any of its companies or divisions. No employee shall work against his/her will or work as bonded/forced labor. Belcan will not tolerate any retaliation against individuals who report or question adjustments, or who participate in investigating such reports. Any type of retaliation may result in disciplinary action, up to and including termination of employment.

Human Trafficking and Slavery Policy

Belcan and its subsidiaries will not tolerate or condone human trafficking or slavery in any part of our organization. This policy is consistent with our core values to protect and advance human dignity and human rights in our global business practices.
Belcan is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy, includes forced labor and unlawful child labor. Belcan also prohibits employees, subcontractors, subcontractor employees, and agents from engaging in practices relating to trafficking in persons, including:

• Destroying or otherwise denying access to an employee’s identity or immigration documents;
• Using misleading or fraudulent practices to recruit employees, such as failing to disclose key terms and conditions of employment;
• Using recruiters that do not comply with local labor laws;
• Charging employees recruitment fees;
• Failing to provide return transportation to certain employees who are brought to a country for the purpose of working on a U.S. Government contract;
• Providing housing that fails to meet host country standards; and
• Failing to provide an employment contract or work document where required by law.

Belcan will take appropriate disciplinary action for violations of these rules, up to and including discharge of employees, subcontractors, or agents.
Belcan will cooperate fully with the U.S. Government or other appropriate governmental authorities in audits or investigations relating to such violations. Employees of Belcan operating companies are required to cooperate in any internal or external investigation of suspected wrongdoing under this policy.