California Transparency in Supply Chains Act

Verification

We conduct audits of 28% of our Tier I direct suppliers every three years to verify that they are not at risk for violating anti-slavery and human trafficking laws. We do not use third-party verifiers. Our own supply chain management (SCM) team completes the verification process using internally developed assessment tools.

Our SCM team is currently unable to verify whether our subcontractors use labor brokers; however, we plan to enhance the audit process in the near future.

Audits

TOK Group is committed to fair labor practices within our supply chain. Our internal auditing team conducts announced audits and supplier surveys of direct suppliers to evaluate their compliance with our anti-slavery and human trafficking company standards. Audits consist of individual and group interviews with supervisors and management, as well as facility tours.

Certifications

TOK Group strongly encourages direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business. However, we do not require such certification.

Accountability

TOK Group publishes the “Compliance Standards of Conduct”, wherein TOK Group abhors slavery & human trafficking, and recognizes that such practices are crimes under state, federal & international law. Any violation or likely violation that is discovered, or committed, must be immediately reported to the point of contact defined by the Company Rules of the TOK Group Company we are employed with.

For internal employees, non-compliance with TOK Group standards of conduct may result in disciplinary action, up to and including termination.

Training

Our SCM team consists of one vice president, and cross-functional membership that includes management, engineers & specialists. Every member of our SCM team receives training on all company policies, practices, and procedures designed to ensure that TOK Group’s supply chain is free of any type of coerced labor, including how to spot warning signs of potential human rights violations.