SUPPLY CHAIN RESPONSIBILITY

On January 1, 2012, the California Transparency in Supply Chains Acts of 2010 (SB 657) (the “Act”) went into effect in the State of California.

The Act seeks the elimination of forced labor, slavery and human trafficking from product supply chains and requires that companies disclose their efforts to ensure their supply chains are free from forced labor, slavery or human trafficking.

As a full member of the Electronic Industry Citizenship Coalition (EICC), we review our supply chain, our suppliers’ practices and our policies and procedures with respect to our suppliers to ensure that our direct supply chain is free from forced labor, slavery or human trafficking, including the following:

  1. Written Policies and Procedures: In connection with joining the EICC, Isola has adopted the EICC Code of Conduct. The EICC Code of Conduct contains internationally recognized labor and human rights standards that include, among other things, freely chosen employment, child labor avoidance, restrictions on working hours, and humane treatment of employees.  Further, the EICC Code of Conduct requires that we operate our business in compliance with all applicable labor laws, rules and regulations, including but not limited to, all laws forbidding the solicitation, facilitation or any other use of slavery or human trafficking, as those terms are defined in the Act.  We have purchase agreements or purchase order terms and conditions in place requiring our suppliers to comply with international standards and applicable laws and regulations that prohibit forced labor, slavery or human trafficking.
  1. Supplier Certifications: In 2015, we will verify that all of our suppliers have certified their compliance with EICC Code of Conduct, including the provisions barring the use of forced labor, slavery or human trafficking.
  1. Third-Party Audits: Shared audits of suppliers are conducted by various EICC members, including Isola, to ensure the suppliers are in compliance with the EICC Code of Conduct. These audits specifically address compliance with all applicable labor laws, rules and regulations governing forced labor, slavery and human trafficking, as set forth in the Act. These audits are announced to suppliers in advance and are conducted in accordance with a uniform EICC audit protocol.  The EICC encourages its members to have these audits conducted by third party auditors, but EICC members may conduct these audits themselves provided that members’ internal company auditors have been specifically approved by the EICC Audit Program Manager.  It is expected that over a period of several years all of the high-risk suppliers within the EICC supply chain will be audited.
  1. Accountability Standards: Isola has a zero tolerance policy for violation of the laws banning forced labor, slavery or human trafficking. If we determine that a supplier violated any of these laws, we will remove the supplier from our approved vendor list.  In addition, any Isola employee who fails to alert executive management of any prohibited activities concerning slavery and trafficking by Isola suppliers will be subject to discipline, up to and including termination of employment.
  1. Employee Training: While personnel working in Isola’s Supply Chain management have reviewed and are familiar with this statement on supply chain responsibility, we currently do not offer formal training on this statement.We are in the process of implementing a new learning management system and plan to expand our training efforts to include supply chain training by the end of 2016.

Isola is committed to taking necessary measures to ensure our direct supply chain is free from forced labor, slavery and human trafficking. We will continue to update our policies and procedures as needed to safeguard against any mistreatment of persons involved in our direct supply chain.