Slavery and Human Trafficking Statement
For Fiscal Year January 1, 2018 through December 31, 2018
This statement has been prepared in accordance with the United Kingdom Modern Slavery Act 2015, Chapter 30, Part 6, Provisions 54 and the California Transparency in Supply Chains Act of 2010 and discloses measures taken by Sensata Technologies Holding plc and its subsidiaries (Sensata) during the 2018 fiscal year to address human trafficking and forced labor within its operations and supply chain.
Structure, Business and Supply Chain
The headquarters of Sensata Technologies Holding plc is located in Swindon, England. Sensata conducts its operations through subsidiary companies that operate business and product development centers primarily in Belgium, Bulgaria, China, Germany, Japan, the Netherlands, South Korea, the United Kingdom, and the United States; and manufacturing operations primarily in Bulgaria, China, Germany, Malaysia, Mexico, the United Kingdom, and the United States.
We develop, manufacture, and sell a wide range of customized sensors and controls that address increasingly complex engineering requirements for specific customer applications and systems such as air conditioning, braking, exhaust, fuel oil, tire, operator controls, and transmission in automotive and heavy vehicle and off-road systems, and temperature and electrical protection and control in numerous industrial applications, including aircraft, refrigeration, material handling, telecommunications, and heating, ventilation and air conditioning systems. In October 2018, we acquired GIGAVAC, LLC, expanding our product offerings to include high voltage contactors and fuses.
We organize our business into two segments: Performance Sensing and Sensing Solutions. As of December 31, 2018, we had approximately 21,650 employees. Approximately 80% of our supplier spend is with 300 suppliers, some of which are located in countries that have been identified by the United States Department of State and the United Nations as having elevated risks of human trafficking and modern slavery.
We are committed to identifying, assessing and eliminating the risks of modern slavery and human trafficking within our internal operations and our supply chain, consistent with the requirements of the United Kingdom Modern Slavery Act of 2015 and the California Transparency in Supply Chains Act of 2010.
We require our employees and suppliers to comply with all applicable country, state, municipal and local laws, orders and regulations, and specifically prohibits human trafficking and slavery. These requirements are set forth in our Code of Business Conduct and Ethics, Human Rights and Working Conditions Policy, and other related corporate policies, and are communicated to our worldwide supply chain through our Supplier Code of Conduct and Supplier Terms and Conditions of Purchase.
Furthermore, we require our suppliers to agree to timely certify compliance with such laws when requested and we have advised our suppliers that they may be audited by us for matters that are covered under our Supplier Code of Conduct, including the prohibition of human trafficking and slavery.
All of our employees, contractors and suppliers may report possible violations of our policies through our Ethics Hot Line. Retaliation against any individual who reports a violation is strictly prohibited under our Code of Business Conduct and Ethics.
In early 2018, we retained a third-party consultant to survey the portions of our direct supply chain that are known to involve U.S. government contracts for indicators of human trafficking and modern slavery using the Slavery Trafficking Risk Template (STRT). In addition, we have evaluated our global supply chain to determine where increased risks of human trafficking and modern slavery may exist. Based on this assessment, we intend to expand our 2019 survey using the STRT to include key direct and indirect suppliers that have operations in high-risk countries.
We currently do not engage an independent auditor to verify supplier compliance with our Supplier Code of Conduct and applicable laws and regulations regarding human trafficking and slavery, nor does we require our suppliers to annually certify that materials incorporated into their products are produced, or services provided to us are provided, in compliance with all laws regarding human trafficking and slavery of the applicable jurisdictions in which they are doing business. We do conduct, however, our own supplier audits to verify compliance, which are typically announced to the supplier prior to the audit.
In addition, we have recently developed a protocol for auditing our suppliers for compliance with international standards for human trafficking and slavery, which we intend to implement as part of our supplier program in 2019.
We maintain internal accountability standards and procedures for employees and suppliers (including contractors) regarding human trafficking and slavery. All employees and suppliers are required to comply with our Code of Business Conduct and Ethics, Human Rights and Working Conditions Policy and Anti-Human Trafficking Policy. Non-compliance by our facilities and suppliers with Federal Acquisition Regulation (“FAR”) 52-222.50 (to the extent such facilities and suppliers are subject thereto) and with our Anti-Human Trafficking Policy are addressed according to our internal policies prepared in accordance with FAR. A failure to promptly correct any violation of these requirements, and specifically the prohibition of human trafficking and slavery, may result in the termination of business with a supplier.
Education and Training
Our Employee Ethics Training Program, which is offered to all employees on a continuing basis at all of our operating locations worldwide, addresses human rights issues and indicators of slavery and human trafficking. In addition, we provide training materials regarding the prohibition of human trafficking and modern slavery to our suppliers during periodic meetings, which are also available through our Supplier Portal.
DATE: April 11, 2019
Martha Sullivan, Director