PREVENTION OF MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Smart Wires is a global leader in grid solutions that leverages patented advanced modular power flow control technology to maximize the use of existing electricity grids. We are based in Durham, North Carolina with an international presence to supply our growing European, Latin American and Asia-Pacific customer bases. We collaborate with many suppliers across the world to design, manufacture, and deliver modular solutions to electricity grid operators. As a team, we are committed to ensuring that we remain a socially, ethically, and environmentally responsible company and we work closely with all our stakeholders to ensure that every aspect of our business is carried out in a responsible manner.

Smart Wires internal policies and procedures have been developed in line with the Ten Principles of the United Nations Global Compact. Our Corporate Social Responsibility Policy (‘CSR Policy’) and Core Values are core to our business ethos, forming the foundation for the internal strategies, policies and procedures that guide our activities on a day-to-day basis.

Our Prevention of Modern Slavery and Human Trafficking Statement (‘Statement’) strengthens our existing culture of zero tolerance to any practices that violate human rights. This statement outlines the policies and procedures that we have put in place to ensure the continued protection of human rights and the prevention of unethical labor practices, such as slavery, servitude, forced or compulsory labor, human trafficking, and child labor, within our company or within our supply chain. This Statement sets a baseline for our ethical standards, which we are committed to building upon in the coming years.

Smart Wires Internal Policies and Procedures

We are committed to the fair treatment of every person we interact with throughout the entire employee lifecycle as we recognize that our employment policies are applicable to not only our current team, but also prospective job candidates and previous employees. All our processes were developed to be clear, robust, and transparent and guarantee the universal fair treatment of every person across business divisions and activities.

Our recruitment and onboarding procedures involve checks on the identity, employment eligibility, and consent to work of potential new hires to ensure the prevention of human trafficking and forced, bonded or compulsory labor within our company. Our onboarding process requires new hires to review and formally sign our Employee Handbook (D000723) which details our key policies and procedures. All team members are provided with the number for our Whistleblower hotline to facilitate the confidential reporting of corruption, fraud, unethical behavior, or any other violations of this Statement. We encourage our team members to report if they have any suspicion of such behavior occurring in our own company or our wider supply chain, regardless of the seniority of their role. This ensures that all employees and contractors are aware of our zero-tolerance approach to any behaviors that are unethical by nature or violate human rights and have continued access to a safe working environment that promotes inclusivity, equity, respect, and collaboration.

Supply Chain Policies and Procedures

We recognize that our supply chain partners play a key role in ensuring that we remain a socially and ethically responsible company, and thus we are committed to building a long-term partnership of mutual trust with suppliers who are committed to adopting the same high ethical standards within their own activities.

We have a robust Supply Chain Management system (SCM) to guide our selection, management, and evaluation of potential and existing suppliers. This SCM is based on the principles of our key Quality Management Systems to ensure that we set the same standards for our suppliers that we set for ourselves.

Our SCM considers the ethical standards upheld by potential suppliers during the Supplier Selection process. We use a tier system as part of our Supplier Selection process to identify those suppliers who can have the biggest impact on our company. By conducting the most comprehensive evaluations on those suppliers, we can minimize the risk of working with suppliers who breach this Statement. We use commercially reasonable efforts to procure from suppliers who at minimum adopt our same high standards for preventing unethical behaviors in their activities.

Commitment to Continual Improvement

We recognize that, as a growing company, we need to regularly monitor, review, and improve our existing policies and procedures to ensure their continued effectiveness when we have a larger workforce, more supply chain partners, and a wider geographical footprint. We endeavor to continuously implement the best practices we come across into our own policies and processes to ensure we maintain the highest ethical standards in our own activities, and across our supply chain. As we continue to work with customers across the world, we intend to meet and exceed their expectations for the ethical standards we uphold.