Disclosure Pursuant to California Transparency in Supply Chains Act of 2010
As specified in its Business Conduct Guidelines, Textron Inc. (“Textron”) is committed to fair employment practices and to following applicable employment law wherever it has operations. This includes complying with laws that prohibit child or forced labor. Textron Aviation Inc., a Textron Business Unit, provides training to its employees on the Business Conduct Guidelines and requires an annual certificate of compliance to be submitted by all designated employees. Breaches of the Business Conduct Guidelines are subject to disciplinary action up to and including termination of employment. In addition, Textron Inc. has adopted a Code of Conduct for Suppliers and Other Business Partners which requires compliance with laws that prohibit harassment, employment discrimination, human trafficking and child or forced labor. When required for compliance with the U.S. Federal Acquisition Regulations, Textron’s Business Units obligate suppliers to submit appropriate certifications and flow down contractual obligations imposed by such regulations. Other than as so described, Textron does not currently (1) engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery; (2) conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains; (3) require direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business; (4) maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking; or (5) provide employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery.