Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires certain companies manufacturing or selling products in California, which currently would include certain Units of IDEX Corporation, to disclose their efforts (if any) to address the issues of human trafficking and slavery in their supply chain and efforts to eradicate each of these from their supply chain.
With a few minor exceptions, the products that IDEX purchases from suppliers do not fall within any of the classes of products that the U.S. Department of Labor has identified in its List of Goods Produced by Child Labor or Force Labor published in 2009, and, to date, IDEX has not observed activity within its supply chain that would trigger any human trafficking or slavery concern. Accordingly, IDEX does not consider human trafficking and slavery to be a significant risk for its supply chain. Although IDEX Units expect their suppliers to comply with applicable laws and frequently obtain agreements and certifications from their key suppliers relating to compliance with applicable laws in supplying products to them, IDEX Units do not verify their supply chain or audit suppliers specifically to evaluate risks of human trafficking and slavery or require their suppliers to certify specifically that products supplied to them were not produced with child labor or slave labor.
IDEX has a Code of Business Conduct and Ethics that applies to all IDEX employees, The Code does not include any standards specific to human trafficking and slavery, and IDEX does not provide training to its employees focused on human trafficking and slavery. However, the Codes does require compliance with the laws, rules and regulations of every country in which IDEX does business, which would include laws on human trafficking and slave labor. In addition, the Code obligates IDEX employees to act in every respect with honesty, fairness and integrity. IDEX employees receive training on the standards and behavior expected of them under the Code.