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SLAVERY AND HUMAN TRAFFICKING STATEMENT


The California Transparency in Supply Chains Act of 2010 requires companies doing business in California to disclose efforts to eliminate slavery and human trafficking from their supply chains. Likewise, the UK Modern Slavery Act 2015 requires commercial organizations to disclose the steps they have taken to ensure there is no modern slavery or human trafficking in their own business and their supply chains. This statement details the systems and controls that Materion has in place to safeguard against slavery and human trafficking in its business and supply chain.

Materion Corporation, including its subsidiaries and affiliates (“Materion”), is committed to ensuring that its employees and suppliers have processes in place to mitigate the risk of human trafficking and slavery from occurring in its business and supply chain.

Materion Corporation: Products and Supply Chain

Headquartered in Cleveland, Ohio, Materion is an advanced materials supplier engaged in the design, development and manufacture of state-of-the-art products and services. Materion operates in 33 locations worldwide, employs over 2,500 employees, serves customers in more than 50 countries and manages a global supply chain of suppliers, contractors and business partners. The majority of Materion’s supply chain partners are located within the United States, but many suppliers, contractors and business partners are located outside the United States.

Materion’s product portfolio is organized into three business groups: the Performance Alloys and Composites group, which includes specialty metals; the Advanced Materials group, which includes the production of high-purity materials; and the Precision Coatings group, which includes optical and large area coating products.

For additional information about our business segments, including the wide variety of products manufactured in each segment, refer to Materion’s 2017 Form 10-K.

Verification of the Supply Chain

Supplier Code of Conduct: Materion prohibits any form of forced labor, including slavery and human trafficking, in our supply chain, and has issued the Materion Supplier Code of Conduct (the “Supplier Code”). The Supplier Code specifically forbids the use of involuntary or forced labor, including unlawful child labor, and requires that suppliers comply with all applicable laws and regulations regarding slavery and human trafficking. The Supplier Code also requires suppliers to ensure that their subcontractors and agents comply with the Supplier Code, and have adequate monitoring and record keeping systems in place to ensure compliance. In addition, Materion requires that suppliers annually acknowledge their understanding of, and compliance with, the Supplier Code. Under the Supplier Code, Materion reserves the right to monitor, review and verify compliance with the Supplier Code. Any concerns relating to potential noncompliance with the Supplier Code are investigated promptly. .

Conflict Minerals: Materion is committed to conducting business so as to protect people and the environment. Materion works with its suppliers to take appropriate actions to ensure that our products do not contain substances identified as conflict minerals under Section 1502 of the Dodd-Frank Act that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or an adjoining country. These actions include conducting reasonable country of origin inquiries and, as necessary, obtaining reliable information on the origin of all conflict minerals that might possibly originate in the DRC or an adjoining country.

Materion successfully completed an audit conducted under the Responsible Minerals Initiative (RMI) and is included on the list of Responsible Minerals Assurance Process (RMAP) Conformant Smelters and Refiners for Gold. The RMI program is a voluntary global initiative developed by the Responsible Business Alliance (RBA) and the Global e-Sustainability Initiative (GeSI) to provide a credible system for companies to substantiate responsible sourcing of conflict minerals.

Internal Accountability Standards

Materion will never use forced, indentured or involuntary labor in any of our operations, nor will it tolerate any instances of slavery or human trafficking. Materion will also never conduct business with any third parties who engage in human trafficking or other forced labor.

This pledge is set forth in Materion’s Code of Conduct (the “Code”). The purpose of the Code is to ensure that Materion conducts business with the highest standards of ethics and integrity and that all Materion employees, officers and directors comply with all company policies, applicable laws and regulations. Any employee, officer, director or supplier who violates these policies is subject to discipline, up to and including termination.

Employees are obligated to report suspected violations of the Code. Employees have a number of resources available to report misconduct, including anonymous reporting through our Ethics & Integrity Hotline and Ethics Website. Our anonymous reporting systems are available 24 hours, 7 days a week and are managed by an independent third party. Any concerns relating to potential noncompliance with Materion’s Code are investigated promptly. Materion has a zero tolerance policy for retaliation. Any employee found to have engaged in retaliatory acts will be subject to disciplinary action, which may include termination of employment.

Training

Annual training is provided to employees on the Materion Code of Conduct. This training addresses the mitigation of the risk of slavery and human trafficking within the supply chain. The employees and management who have direct responsibility for the supply chain are aware of their obligation to mitigate these risks and are empowered to immediately address and resolve any event of potential noncompliance.

Jugal K. Vijayvargiya
President & CEO

The Board of Directors of Materion Corporation approved this statement at its board meeting held on May 2, 2018. This is Materion Corporation’s statement for the financial year ended December 31, 2017.