Modern Slavery Act Statement

Our structure, business and supply chain

Headquartered in the UK, Meggitt PLC is a global engineering group specialising in smart engineering for extreme environments – components and sub-systems providing critical functionality in challenging market applications within civil aerospace, military and energy markets. Our products are on more than 71,000 aircraft, hundreds of turbines and oil and gas platforms, as well as thousands of land vehicles worldwide. We employ around 11,000 people across over 45 manufacturing facilities in Europe, North America and Asia. Organisationally, our business is divided into four divisions, which are described in more detail elsewhere on our website.

Our supply chains are diverse, both geographically, and in the nature of the suppliers we work with, in Europe, the US and Asia. We have a direct supply chain that exists to support the production of our engineered products, supplying services and parts such as machining, electronic and hydraulic components, seals and gaskets and carbon components. We also have an indirect supply chain for the things that do not go directly into our products, servicing the operational needs of our manufacturing facilities and offices.

Our policies in relation to slavery and human trafficking

Our Code of Conduct states that Meggitt PLC and all subsidiary companies will conduct business fairly, impartially, and in full compliance with all applicable laws and regulations. We are firmly committed to integrity, honesty and respect for others in all our business relationships, including those with customers, suppliers, communities where we conduct business, and amongst employees. This means that all our businesses, wherever they are located in the world and wherever they have dealings in the world, are required to respect people and to value their diversity.

Our Corporate Responsibility Policy states that Meggitt PLC recognises the important responsibility it has to balance the interests of its shareholders, employees, customers, suppliers, and the wider community and recognises that the responsible and sustainable development of our business is very important for its long term success. The policy commits us to ensuring that (i) Meggitt and our employees do not engage in practices such as slavery, human trafficking, forced labour and child labour and do not violate applicable laws and regulations relating to slavery, human trafficking, forced labour and child labour; and (ii) that we take all reasonable measures to ensure that our suppliers and other entities acting on our behalf do not engage in practices or violate applicable laws and regulations relating to slavery, human trafficking, forced labour and child labour.

A risk based approach

Our business is principally involved in the delivery of highly technical and complex engineered products to predominantly long-established, primarily global companies or governmental customers, and we believe our exposure to the risks of modern slavery is low within our industry. However, this assessment will be kept under review and if circumstances change, we will review our approach accordingly.

• All of our businesses, regardless of where they are based, are expected to comply in all respects with our Code of Conduct and Corporate Responsibility Policy.
• In 2016, we amended our supplier terms and conditions which apply to our suppliers (and are in the process of amending the supporting supplier quality requirements), to reflect our expectation that our suppliers will comply with our policies on slavery, human trafficking, forced labour and child labour. The Board agreed that a risk based review of the supply chain is undertaken on a regular basis and suppliers located in higher risk countries are specifically contacted to confirm that they understand our policies on slavery, human trafficking, forced labour and child labour.

Adherence to anti-slavery

• Our businesses confirm on an annual basis that they have complied with our policies, including the Corporate Responsibility Policy and Code of Conduct, and for 2018 they have specifically confirmed that they are not aware of any individuals who have been employed by the business as a result of slavery, human trafficking, forced labour or child labour and are not aware of any individuals working for the businesses’ suppliers, contractors or sub-contractors who have been employed as a result of slavery, human trafficking, forced labour or child labour or who are employed in violation of any applicable laws or regulations regarding slavery, human trafficking, forced labour or child labour.
• For suppliers, we have assessed to be higher risk, we have sought to oblige them to confirm their compliance with our policy which prohibits engaging in practices such as slavery, human trafficking, forced labour and child labour as set out in our Corporate Responsibility Policy.

Training

• Meggitt has a comprehensive Ethics Programme, including Ethics and Business Conduct and Anti-Corruption Policies and an independent whistleblowing hotline which enables employees to raise questions or concerns confidentially or anonymously, 24 hours a day, 7 days a week from anywhere in the world. There is also a dedicated US Global Human Trafficking Hotline. Each site also has a designated Ethics Champion who is available to assist employees who have questions or concerns;
• All employees are required to undertake mandatory training on our Code of Conduct and we carry out other regular training on business conduct and anti-corruption where examples are given on how to apply the principles and provisions laid out in our policies; and
• HR and procurement teams receive specific training on how to recognise modern slavery.

Progress to date

During 2018:

• We re-evaluated our supply chain to identify higher risk suppliers.
• We had no reported incidences or indicators of modern slavery in our business or supply chain.

The above statement sets out the steps taken by Meggitt PLC and its subsidiary companies Meggitt (UK) Limited and Meggitt Aerospace Limited under the Modern Slavery Act 2015. It was approved by the Board of Meggitt PLC, Meggitt UK Limited and Meggitt Aerospace Limited on 21 February 2019 for the financial year ended 31 December 2018 and signed by Tony Wood, Chief Executive.