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 60,000 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 50 manufacturing facilities in Europe, North America and Asia. Organisationally, our business is divided into five 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 should be undertaken and that suppliers located in higher risk countries should be specifically contacted to ensure 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 2017 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

• To ensure our employees are aware of and understand the risks of modern slavery and human trafficking in our supply chains, we provide training to key staff as necessary;
• All employees undertake mandatory training on our Code of Conduct; and
• HR and procurement teams have received refresher training in 2017.

Approved by the Board of Directors of Meggitt PLC on 22 February 2018

Tony Wood
Chief Executive
8 March 2018