California Transparency in Supply Chains Act (2010) Disclosure Cal. Civ. Code §1714.43

At SPX Corporation (“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 Corporation 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.

United Kingdom Modern Slavery Act (2015) Statement §54

Statement Pursuant to the
Modern Slavery Act 2015 (UK) for the
Fiscal Year 1 January 2020 – 31 December 2020
 

This Statement of SPX Cooling Technologies UK Limited (“Cooling”),Radiodetection Limited (“Radiodetection”), ULC Robotics International Limited (“ULC”), and Sealite United Kingdom Limited (“Sealite”) (the “Companies”) for the financial year commencing 1 January 2020 and ending 31 December 2020 (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.

Organizational Structure

The Companies are subsidiaries of SPX Corporation (“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 Cooling is Marley Cooling Tower (Holdings) Limited and 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 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 to ensure that all employees and temporary workers have access, who may 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. 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/), 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 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 and Values 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 Cooling Technologies UK Limited Radiodetection Limited
By: /s/ John W. Nurkin By: /s/ John W. Nurkin
Name: John W. Nurkin Name: John W. Nurkin
Title: Director Title: Director
Date: June 9, 2021 Date: June 9, 2021
ULC Robotics International Limited Sealite United Kingdom Limited
By: /s/ John W. Nurkin By: /s/ John W. Nurkin
Name: John W. Nurkin Name: John W. Nurkin
Title: Director Title: Director
Date: June 9, 2021 Date: June 9, 2021