UNITED KINGDOM MODERN SLAVERY ACT STATEMENT
This is a statement made pursuant to section 54(1) of the Modern Slavery Act 2015. The statement sets out the steps the Collins Aerospace group, through all of its operating companies in the United Kingdom (as listed below), has taken during the financial year ending 30 December 2018 (the “Reporting Period”) to ensure slavery and human trafficking is not taking place in any part of its own business, or supply chain.
Collins Aerospace is a supplier of technologically advanced aerospace and defense products. We design, manufacture and service systems and components and provide integrated solutions for commercial, regional, business and military aircraft, helicopters, airports and other platforms. Collins Aerospace is part of United Technologies Corporation which provides high-technology systems and services to the building and aerospace industries through its four business segments: Otis, UTC Climate, Controls & Security, Pratt & Whitney, and Collins Aerospace (collectively, “UTC”).
UTC’s Code of Ethics (the “Code”) is the foundation of our culture. First adopted in 1990, our Code sets forth values and commitments that guide ethical decision making everywhere we do business. The Code applies to UTC and its controlled entities, worldwide. Among other things, the Code includes the following statement:
UTC respects and protects human rights by:
Each year, UTC requires its employees to certify they have read and will comply with the Code. Compliance with the requirements of the Code is expected behavior for all UTC employees. Violations of these requirements will result in appropriate corrective action.
UTC Ombudsman Program
Employees and third parties (including suppliers) who observe or suspect a violation of the Code may ask a question or raise concerns in complete confidence through UTC’s Ombudsman Program. Additional information about the UTC Ombudsman Program is available here.
UTC made and continues to make training available to company management and employees on recognizing and mitigating the risk of human trafficking and slavery in supply chains. Employees with direct responsibility for supply chain management are assigned this training during their second year in that job function.
Supply Chain Expectations
To produce superior products in a responsible manner, we need suppliers who meet high standards for business practices, environmental responsibility and operational excellence. Accordingly, our suppliers are subjected to robust selection processes and criteria including verification against government denied party lists.
UTC’s standard contract terms and conditions of purchase require suppliers to comply with all applicable laws and regulations. In addition, our standard contract terms require suppliers to adopt and comply with a code of conduct or policy statement regarding business conduct, ethics and compliance that satisfies, at a minimum, the principles set forth in the Supplier Code of Conduct (“Supplier Code”).
The Supplier Code sets forth UTC’s expectations for our suppliers, and aligns with the expectations we maintain for our own directors, officers, employees and representatives. Among other things, the Supplier Code requires suppliers to ensure child labour is not used in the performance of their work, whether or not related to UTC business. It also requires suppliers to fully comply with laws and regulations prohibiting human trafficking. This includes prohibiting the use of forced, bonded or indentured labour, involuntary prison labour, slavery, or trafficking in persons. Additionally, the Supplier Code states our suppliers will allow UTC and/or its representatives to assess their compliance, as well as the compliance of the suppliers’ business partners, with the expectations set forth in the Supplier Code in performing work for UTC, including on-site inspection of facilities. The Supplier Code is available here.
Further, UTC’s standard contract terms require suppliers to have management systems, tools and processes in place that (a) ensure compliance with applicable laws, regulations, and requirements set forth in the Supplier Code; (b) promote an awareness of and commitment to ethical business practices; (c) facilitate the timely discovery, investigation, disclosure and implementation of corrective actions for violations; and (d) provide training to employees on compliance requirements, including the expectations set forth in the Supplier Code.
UTC’s standard contract terms and conditions of purchase also include Federal Acquisition Regulation (“FAR”) clause 52.222-50, Combating Trafficking in Persons, in its subcontracts, including commercial item subcontracts, which are placed with direct suppliers in support of UTC’s U.S. Government contracts. This clause must be flowed down to sub-tier suppliers that support U.S. Government prime contracts and contains a reporting obligation to notify the Contracting Officer and the agency Inspector General immediately of any credible information we receive from any source that alleges an employee or subcontractor has engaged in conduct that violates the policy. UTC requires suppliers to submit certifications where required by the FAR.
In the event a supplier commits any material violation of law relating to basic working conditions and human rights in their performance of work of their subcontracts with UTC, UTC has the right to terminate those subcontracts for default.
Signed by Christoph T. Feddersen – Vice President & General Counsel
29 March 2019