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California Transparency in Supply Chains Act Disclosure

California Transparency in Supply Chains Act Disclosure

We at VTech Communications, Inc. (“VTech”, “Snom”, “our”, “we” or “us”) make this disclosure pursuant to the California Transparency in Supply Chains Act of 2010, a law which is designed to increase the amount of information manufacturers and retailers make public regarding their efforts to address the issue of slavery and human trafficking in their supply chains.

We are committed to conducting our business in a lawful and ethical manner, and we expect the same from our suppliers. As part of this commitment, we have no tolerance for slavery or human trafficking in our supply chain.

We have taken the following steps to eradicate slavery and human trafficking from its supply chain:

Supplier Agreements. We do not require its suppliers to certify that materials incorporated into their products comply with the slavery and human trafficking laws of the countries in which they are doing business. However, our standard purchasing agreement requires suppliers to comply with all applicable laws, including laws that govern slavery, human trafficking and other exploitative labor practices.

Company Responsibility. We strive to establish and maintain close working relationships with its suppliers. We do not rely upon third parties to verify its product supply chains in order to evaluate and address risks of slavery and human trafficking.

Audits. VTech’s own factory in China is audited frequently by major U.S. retailers, partly for the purpose of establishing compliance with applicable laws and their own corporate policies on employment and workplace standards. We do not conduct, or engage third parties to conduct, onsite audits of its suppliers; however, many of those suppliers have their own codes of conduct and auditing programs which assist them in complying with our requirement that they operate their factories in accordance with all applicable laws.

Employee Training and Accountability. At this time, we do not provide employees with training on slavery and human trafficking. However, employees who interact with suppliers are expected to report any potentially unlawful or unethical conduct that comes to their attention, including the presence of slavery or human trafficking in our supply chain. Under our Whistleblower Policy, any such report will be promptly and appropriately investigated.

This Policy applies to all of the products offered by VTech Communications, Inc. and Snom, Inc.