California Transparency in Supply Chains Act (2010) Disclosure Cal. Civ. Code §1714.43
At SPX Technologies (“SPX”), principled business practices are integral to our corporate Values. As a company, we conduct business in a way that respects human rights. We provide equal opportunity in our employment practices and seek to ensure that all persons are treated with fairness and dignity. We are committed to providing a work environment that is healthy, safe, and free from all forms of illegal discrimination or harassment, and we seek to comply with all laws regulating the way our products are manufactured. We require that our employees respect the rights, dignity, and self-esteem of all persons in any way involved with SPX business and prohibit taking any unfair advantage of anyone through manipulation, concealment, misrepresentation of facts, or any other unfair practices. SPX works to meet the needs of a growing global community in a responsible manner and fully supports the protection and advancement of basic human rights throughout its operations.
We evaluate and address direct supply chain risks by requiring suppliers to abide by our contractual terms and conditions, including the condition that they must comply with all applicable laws, which include human trafficking laws. In addition, we maintain a compliance hotline, hosted by a third party, that enables any person to submit concerns regarding human trafficking occurring within our supply chains. All reports to our hotline are investigated thoroughly at the direction of our Compliance Director, with remedial action taken against suppliers if warranted. As a matter of standard practice, we do not utilize third parties to evaluate and verify supply chain human trafficking risks.
We expect our supply chain managers to engage with suppliers and to make assessments of any questionable activity and to ensure that supplier practices conform to our contractual terms and conditions, and to our standards and expectations. We do not conduct audits of suppliers to evaluate, or require suppliers to certify to, compliance with company standards or laws for human trafficking. We do not conduct independent, unannounced audits.
The SPX Technologies Code of Ethics and Business Conduct (the “Code”) includes a specific section dedicated to our commitment to uphold human rights and source responsibly, including our commitment to following all applicable labor and human rights laws and source responsibly through the supply chain. All SPX employees, officers, and directors are required to adhere to the Code, our Values, and all applicable laws. Failure to do so results in disciplinary action, up to and including termination of employment. Moreover, periodic training of employees includes instruction that even conduct that is legal, or not legally restricted, is not permissible if it is not also ethical. For our employees with direct responsibility for supply chain management, we conduct mandatory training on forced labor, slavery, and human trafficking, including with respect to mitigation of risks within the supply chains of products. We conduct this training for the applicable employees at hire and we conduct refresh training periodically thereafter.
SPX Technologies Statement on Forced Labour, Child Labour, Human Trafficking and Modern Slavery
For
Fiscal Year 2024
Read in French
This Statement provides an overview of the efforts that SPX Technologies, Inc. (together with its subsidiaries, “SPX,” for the reporting period from January 1, 2024, to December 31, 2024 (“fiscal year 2024”)1, to ensure that slavery, forced labour, child labour and human trafficking is not taking place in our business, including within our supply chain. We have prepared this Statement on a consolidated basis for SPX – although not all the entities in our consolidated group are subject to each or any of the California Transparency in Supply Chains Act, UK Modern Slavery Act, or the Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act – because we have a single compliance program, with one set of policies, relating to slavery, forced labour, child labour and human trafficking. To the extent applicable, the signature pages in this Statement include additional disclosures specific to the entities required to prepare a statement under one or more of the laws listed above.
In this Statement, SPX uses “forced and child labour” to refer to forced labour, slave labour, prison labour, indentured labour, bonded labour, human trafficking, child labour and similar conduct. A listing of the Company’s subsidiaries is available in its latest Form 10-K filed with the United States Securities and Exchange Commission.
SPX Overview and Policies
SPX Technologies, a Delaware corporation based in Charlotte, North Carolina USA, and its consolidated subsidiaries are a diversified, global supplier of infrastructure equipment serving the HVAC and detection and measurement markets, offering a wide array of highly engineered infrastructure products with strong brands.
SPX has operations via subsidiaries globally, specifically including three (3) entities in the United Kingdom and two (2) entities in Canada, which are jointly filing this report:
- SPX European Holdings Limited (United Kingdom), Radiodetection Limited (United Kingdom), SPX Sabik Europe Holdings Limited (United Kingdom), (collectively referred to as the “UK Filing Entities”); and
- T. A. Morrison & Co., Inc. (in Ontario, Canada) and Ingénia Technologies Inc. (in Québec, Canada) (collectively referred to as the “Canadian Filing Entities”).
HVAC solutions offered by our businesses include packaged and process cooling equipment, engineered air movement and handling solutions, residential and commercial boilers, electrical heating, and ventilation products.
Our detection and measurement product lines encompass underground pipe and cable locators, inspection and rehabilitation equipment, robotic systems, transportation systems, communication technologies, and aids to navigation. Our detection and measurement solutions enable utilities, telecommunication providers and regulators, and municipalities and transit authorities to build, monitor and maintain vital infrastructure.
At SPX, principled business practices are integral to the SPX corporate Values. As a company, SPX conducts business in a way that respects human rights. SPX provides equal opportunity in employment practices and seeks to ensure that all persons are treated with fairness and dignity.
SPX is committed to providing a working environment that is healthy, safe, and free from all forms of illegal discrimination or harassment and seeks to comply with all applicable laws regulating the way products are manufactured.
SPX requires that employees respect the rights, dignity, and self-esteem of all persons in any way involved with SPX’s business and prohibits taking any unfair advantage of anyone through manipulation, concealment, misrepresentation of facts, or any other unfair practices.
SPX works to meet the needs of its global community in a responsible manner and fully supports the protection and advancement of basic human rights throughout its operations. SPX is committed to ensuring modern slavery cannot exist in its own business and to eliminating modern slavery (including slavery, servitude, forced or compulsory labour, and human trafficking) throughout its supply chains.
A common standard of policies and procedures in support of this commitment are adopted and applied across the SPX group of companies, and therefore provide the basis for this Statement, as set out below.
- The Code of Ethics Business Conduct (the “Code”) The Code includes a specific section dedicated to SPX’s commitment to upholding human rights and sourcing responsibly, including its commitment to following all applicable labour and human rights laws and sourcing responsibly through the supply chain. The Code can be found here: The Code
- SPX’s Human Rights Policy (the “Policy”): The Policy
- SPX’s Supplier Code of Conduct (the “Supplier Code”): Supplier Code
- SPX’s Values (the “Values”): Values
SPX’s Supply Chain
SPX procures a variety of products and services from suppliers around the world. Given the nature and geography of SPX’s business, its supply chain is both extensive and diverse. SPX acknowledges the elevated risk of modern slavery, forced labour, child labour and human trafficking in certain countries of the world.
SPX evaluates and addresses direct supply chain risks by requiring suppliers to abide by contractual terms and conditions, including the condition that they must comply with all applicable laws, which include human trafficking and anti-slavery laws. SPX provides training to supply chain managers to look out for any “red flags” by engaging with suppliers, to make assessments of any questionable activity and to ensure that supplier practices conform to contractual terms and conditions, and to SPX standards and expectations.
In addition, SPX maintains a compliance hotline, hosted by a third party, that enables any person to voice concerns and report potential violations of the Policy , the Supplier Code, the Values and the Code . The hotline is accessible online and via phone, and any person is able to submit concerns regarding human trafficking occurring within SPX’s supply chains using this hotline. All reports to the hotline are investigated thoroughly at the direction of the SPX Compliance Director, with remedial action taken against suppliers if warranted.
Moreover, the contact information for the above-mentioned hotline is displayed at all sites globally (and in local language where applicable) to ensure that all employees and temporary workers have access to voice concerns and report potential violations of the Code, the Supplier Code, the Policy and the Values.
Supply Chain, Risk Assessment and Due Diligence
SPX is committed to taking steps to ensure that human trafficking and forced labour are not taking place in its supply chain or business. SPX is aware that a complex global supply chain may be associated with risks of modern slavery when raw materials, components, products, or services pass through multiple tiers of suppliers.
Before bringing third parties into the SPX supply chain, an assessment is made of each company to assure ourselves that they are ethically appropriate and have suitable measures in place to provide us with the confidence that the risks of modern slavery and human trafficking are being adequately addressed. In the event that a candidate supplier is deemed to be misaligned ethically with SPX’s ethical stance SPX will not engage them.
As stated above, SPX requires suppliers to abide by contractual terms and conditions, including the condition that they must comply with the Supplier Code together with all applicable laws, which include anti-modern slavery and human trafficking laws. SPX’s standard contracts also specifically require the counterparties not to engage in corrupt or unethical practices. Failure to comply with the requirements of SPX’s contracts will be a breach of contract that may lead to termination.
Training
For employees with direct responsibility for supply chain management, we conduct mandatory training on forced labour, slavery, and human trafficking, including with respect to mitigation of risks within the supply chains of products. We conduct this training for the applicable employees at the time of hire (or shortly after an acquisition, as applicable) and we conduct refresher training periodically thereafter.
All SPX employees, officers, and directors are required to adhere to the Code ,the Policy, the Values and all applicable laws. Failure to do so results in disciplinary action, up to and including termination of employment. Periodic training of employees includes instruction that even conduct that is legal, or not legally restricted, is not permissible if it is not also ethical.
Remediation
If SPX was to identify an instance of forced labour or child labour, we would work to develop a process and remediation plan so that the appropriate measures are deployed to mitigate future occurrences. If the relevant third party failed to remedy the position to our satisfaction, we would terminate all engagement with such third party. SPX did not identify any modern slavery, human trafficking, or forced labour of child labour practices in our supply chains in the reporting period and therefore did not need to implement measures to remediate such practices or the loss of income resulting from eliminating such practices.
By December 31, 2024, no incidents of forced labour or child labour were reported or identified within SPX’s operations or supply chain. As a result, remediation measures were not required to correct any forced labour or child labour or to compensation for the loss of income to vulnerable families.
Effectiveness
SPX conducts mandatory training on modern slavery, forced labour, slavery, and human trafficking, including with respect to mitigation of risks within the supply chains of products within all its business segments. The trainings are conducted for all employees that are identified to be involved and engaged with our third parties at the time of hire (or shortly after an acquisition, as applicable) and we conduct refresher training periodically thereafter.
As SPX continues to develop its program to prevent modern slavery, forced labour or child labour risks within SPX in 2025, we will consider and implement additional measures to adapt and strengthen our trainings and processes.
Next Steps
The management of SPX take and will continue to take a zero-tolerance approach to forced labour or child labour and will react accordingly to any transgression by its staff or suppliers. SPX recognizes that the risks from forced labour or child labour are constantly evolving. SPX also recognizes that efficient methods to identify and address forced labour or child labour will be developed and enhanced. SPX remains focused on maintaining the highest standards of ethical and business integrity across their businesses and supply chains, and will continue to monitor and evaluate such developments. SPX is committed to its Supplier Code, the Code, the SPX Values and Policy and in the coming fiscal year will continue its practice of ensuring that its policies and procedures are fit-for-purpose.
Approval
This Statement was approved and is signed below on behalf of the Filing Entities and SPX Technologies, Inc.
Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act
Solely for purposes of compliance with the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Canadian Act”), this Statement has been approved on behalf of SPX Technologies, Inc., T. A. Morrison & Co., Inc., and Ingénia Technologies Inc., on May 28, 2025, by Written Resolutions pursuant to subparagraph 11(4)(b)(i) of the Canadian Act. This Report is also available on our company website at www.spx.com.
In accordance with the requirements of the Canadian Act, and in particular section 11 thereof, the respective undersigned, in the capacity as stated below in the signature block, attest that they have reviewed the information contained in the report for SPX Technologies, Inc., T. A. Morrison & Co., Inc. and Ingénia Technologies Inc. Based on their knowledge, and having exercised reasonable diligence, they attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Canadian Act, for the reporting year listed above.
I confirm, in my capacity of Chief Legal Officer and Vice President of SPX Technologies, Inc., that this Statement has been approved.
| By: |  |
By: |  |
|
| Name: | Cherée H. Johnson | Name: | Wayne McLaren | |
| Title: | Chief Legal Officer & Vice President | Title: | Director, Vice President and Treasurer w/i T. A. Morrison & Co., T. A. Morrison & Co. | |
| Date: | May 28, 2025 | Date: | May 28, 2025 | |
| By: | |
|||
| Name: | Wayne McLaren | |||
| Title: | Director, Vice President and Treasurer w/i T. A. Morrison & Co., T. A. Morrison & Co. | |||
| Date: | May 28, 2025 |
UK Modern Slavery Act
In accordance with the requirements of the UK Modern Slavery Act, I, this Statement has been approved on behalf of SPX European Holdings Limited, Radiodetection Limited, SPX Sabik Europe Holdings Limited.
For the purposes of the UK Modern Slavery Act 2015, this Statement has also been approved by the boards of each Company set out below and is signed on their behalf by a director of the approving board of each Company.
| SPX European Holdings Limited | Radiodetection Limited | |||
| By: |  |
By: | |
|
| Name: | Andrew Bruce | Name: | Wayne McLaren | |
| Title: | Director | Title: | Director | |
| Date: | May 28, 2025 | Date: | May 28, 2025 | |
| SPX Sabik Europe Holdings Limited | ||||
| By: | |
|||
| Name: | Wayne McLaren | |||
| Title: | Director | |||
| Date: | May 28, 2025 | |||
(1) Please note that Ingénia Technologies Inc. (“Ingénia”) was acquired by SPX Technologies, Inc. on February 6, 2024. Therefore, even though Ingénia is now jointly filing with SPX Technologies for the financial exercise ending on December 2024, for the period of filing ending on May 31, 2024, Ingénia filed.
United Kingdom Modern Slavery Act (2015) Statement §54
Statement Pursuant to the
Modern Slavery Act 2015 (UK) for the
Fiscal Year 1 January 2023 – 31 December 2023
This Statement of, Radiodetection Limited (“Radiodetection”), , SPX European Holdings Limited (“EHL”), and SPX Sabik Europe Holdings Limited (“Sabik”)(the “Companies”) for the financial year commencing 1 January 2023 and ending 31 December 2023 (the “Fiscal Year”) is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) of the United Kingdom and constitutes the Companies’ slavery and human trafficking statement in accordance with the Act.
Organisational Structure
The Companies are subsidiaries of SPX Technologies, Inc. (“SPX”), a supplier of highly-engineered products and technologies, holding leadership positions in the HVAC and detection and measurement markets. SPX is incorporated in the state of Delaware, USA and is based in Charlotte, North Carolina, USA. The ultimate United Kingdom-based parent of Radiodetection is SPX European Holding Limited.
Overview
At SPX, principled business practices are integral to the SPX corporate Values. As a company, SPX conducts business in a way that respects human rights. SPX provides equal opportunity in employment practices and seeks to ensure that all persons are treated with fairness and dignity. SPX is committed to providing a working environment that is healthy, safe, and free from all forms of illegal discrimination or harassment, and seeks to comply with all applicable laws regulating the way products are manufactured. SPX requires that employees respect the rights, dignity, and self-esteem of all persons in any way involved with SPX’s business and prohibits taking any unfair advantage of anyone through manipulation, concealment, misrepresentation of facts, or any other unfair practices.
SPX works to meet the needs of its global community in a responsible manner and fully supports the protection and advancement of basic human rights throughout its operations. The Companies are committed to the United Kingdom government’s efforts to eliminate modern slavery (including slavery, servitude, forced or compulsory labour, and human trafficking) throughout their supply chains. A common standard of policies and procedures in support of this commitment are adopted and applied across the SPX group of companies, and therefore provide the basis for this Statement, as set out below.
Supply Chains
SPX procures a variety of products and services from suppliers around the world. Given the nature and geography of SPX’s business, its supply chain is both extensive and diverse. SPX acknowledges the elevated risk of modern slavery in certain countries of the world.
SPX evaluates and addresses direct supply chain risks by requiring suppliers to abide by contractual terms and conditions, including the condition that they must comply with all applicable laws, which include human trafficking laws. SPX expects supply chain managers to engage with suppliers, to make assessments of any questionable activity and to ensure that supplier practices conform to contractual terms and conditions, and to SPX standards and expectations.
In addition, SPX maintains a compliance hotline, hosted by a third party, that enables any person to voice
concerns and report potential violations of the SPX Supplier Code of Conduct (the “Supplier Code”) and SPX Code of Ethics and Business Conduct (the “Code”). The hotline is accessible online and via phone, and any person is able to submit concerns regarding human trafficking occurring within SPX’s supply chains using this hotline. All reports to the hotline are investigated thoroughly at the direction of the SPX Compliance Director, with remedial action taken against suppliers if warranted.
Moreover, the contact information for the above-mentioned hotline is displayed at all sites globally (and in local language where applicable) to ensure that all employees and temporary workers have access to voice concerns and report potential violations of the Code.
Policies and Training
The Code includes a specific section dedicated to the company’s commitment to upholding human rights and sourcing responsibly, including its commitment to following all applicable labour and human rights laws and sourcing responsibly through the supply chain. As an additional indication of the importance of human rights to SPX and the Companies, SPX recently adopted a Human Rights Policy (https://www.spx.com/wp-content/uploads/2022/04/Human-Rights-Policy-FINAL.pdf). All SPX employees, officers, and directors are required to adhere to the Code (https://www.spx.com/our-company/commitment-to-compliance/), company Values (https://www.spx.com/our-company/mission-and-values/), SPX Policies and all applicable laws. Failure to do so results in disciplinary action, up to and including termination of employment. Periodic training of employees includes instruction that even conduct that is legal, or not legally restricted, is not permissible if it is not also ethical.
For employees with direct responsibility for supply chain management, we conduct mandatory training on forced labour, slavery, and human trafficking, including with respect to mitigation of risks within the supply chains of products. We conduct this training for the applicable employees at the time of hire (or shortly after an acquisition, as applicable) and we conduct refresher training periodically thereafter.
Next Steps
The management of SPX takes and will continue to take a zero-tolerance approach to modern slavery and human trafficking and will react accordingly to any transgression by its staff or suppliers.
SPX recognises that the risks from modern slavery and human trafficking are constantly evolving. SPX also recognises that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced. SPX remains focused on maintaining the highest standards of ethical and business integrity across their businesses and supply chains, and will continue to monitor and evaluate such developments. SPX is committed to its Code, Values and Policies and in the coming fiscal year will continue its practice of ensuring that its policies and procedures are fit-for-purpose.
Board Approvals and Signatures
This Statement has been approved by the boards of each Company and is signed below on their behalf by a director of each Company.
| SPX European Holdings Limited | Radiodetection Limited | |||
| By: |  |
By: | |
|
| Name: | John W. Nurkin | Name: | John W. Nurkin | |
| Title: | Director | Title: | Director | |
| Date: | May 22, 2024 | Date: | May 22, 2024 | |
| SPX Sabik Europe Holdings Limited | ||||
| By: | |
|||
| Name: | John W. Nurkin | |||
| Title: | Director | |||
| Date: | May 22, 2024 | |||
