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Materion Corporation, including its subsidiaries and affiliates (“Materion”), will never use forced, indentured or involuntary labor in any of our operations nor will we tolerate any instances of forced labor or human trafficking.  We will also never conduct business with any third parties who engage in human trafficking or other forced labor. This commitment is set forth in Materion’s Code of Conduct, which applies to all Materion employees, officers and directors. Training is provided to employees generally on the Code of Conduct requirements, and this training generally 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.  

Materion similarly 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, among other things, 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 that suppliers ensure that their subcontractors and agents comply with the Supplier Code, and have adequate monitoring and record keeping systems in place to ensure compliance.  The Supplier Code expressly provides that Materion reserves the right to monitor, review and verify compliance with the Supplier Code.  In addition, key direct material suppliers are required to annually acknowledge their compliance with the Supplier Code through an on-line certification procedure.  

Materion has introduced an enhanced supplier audit program that targets key direct material suppliers to ensure compliance with Materion’s strict policy against the use of forced, indentured, or involuntary labor.  This program allows Materion to independently verify, evaluate and address risks of human trafficking and slavery within the supply chain.  As set forth above, the annual certification process requires key direct suppliers to certify that all materials or products supplied to Materion comply with the laws regarding slavery and human trafficking in all countries in which they are doing business.  This verification and audit process is conducted internally and at this time is not conducted through independent unannounced audits.

Any concerns relating to potential noncompliance with Materion’s Code of Conduct or the Supplier Code are investigated promptly.  Any employee, officer, director or supplier who violates these policies is subject to discipline, up to and including termination.