California Transparency In Supply Chains Act Disclosure

The California Transparency in Supply Chains Act (the "Act") requires certain companies doing business in California to disclose information regarding their efforts to address the risk of slavery and human trafficking in their supply chains. Newport Corporation ("Newport") is committed to conducting business ethically and in compliance with global labor and human rights laws, and we expect the same of our suppliers. Newport maintains a Supplier Code of Conduct (the "Code of Conduct"), and by conducting business with Newport, Suppliers agree to adhere to the requirements of the Code of Conduct, which include prohibitions on forced labor, human trafficking and child labor, and require compliance with wage and hour laws and humane treatment, non-discrimination and freedom of association of employees.

As required by the Act, Newport is disclosing the extent to which it does the following:

  1. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery, including whether the verification was conducted by a third party.

    In doing business with Newport, suppliers are required to represent that they comply with the Code of Conduct, including the aforementioned prohibitions on forced labor, human trafficking and child labor, and requirements of compliance with wage and hour laws and humane treatment, non-discrimination and freedom of association of employees. Newport conducts audits of certain suppliers to ensure compliance with our quality management systems and performance standards, applicable laws and regulations and our suppliers' contractual obligations to us. Newport does not utilize third parties to conduct these audits, and they have not historically included the assessment of human trafficking risks.

  2. Conducts supplier audits to evaluate compliance with company standards for trafficking and slavery in supply chains.

    As mentioned above, Newport conducts audits of certain suppliers to ensure compliance with our quality management systems and performance standards, applicable laws and regulations and our suppliers' contractual obligations to us. These audits are not independent and unannounced, and have not historically included the assessment of human trafficking risks.

  3. Requires direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

    In doing business with Newport, suppliers are required to represent that they comply with the Code of Conduct. The Code of Conduct mandates that Suppliers require their sub-suppliers to comply with all applicable laws, rules and regulations, and promote among their sub-suppliers other principles and requirements that are consistent with the Code of Conduct, including the aforementioned prohibitions on forced labor, human trafficking and child labor, and requirements of compliance with wage and hour laws and humane treatment, non-discrimination and freedom of association of employees.

  4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

    Newport's employees are held to high ethical standards, and our Code of Business Conduct and Ethics prohibits employees from violating any law or our standards of conduct, including with respect to slavery and human trafficking. Employees who violate this policy are subject to disciplinary action, including immediate termination. We expect Newport contractors to abide by the same ethical standards, and those who violate these standards may be subject to immediate termination of their business with Newport.

  5. Provides 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.

    Newport's procurement team receives annual training, including with respect to compliance with company policies and applicable laws. However, that training has not specifically addressed mitigating supply chain risks of human trafficking and slavery.