Statement for Fiscal Year ending 31 December 2019

I.            Verification
ETC does not presently conduct assessments of its suppliers to verify their compliance with anti-slavery and human trafficking regulations. ETC does not use third party verifiers. ETC is unable to verify whether any subcontractors use labor brokers.

II.            Audit
ETC does not presently audit its suppliers to evaluate their compliance with anti-slavery and human trafficking regulations.

III.            Certification
ETC’s Purchase Order Terms and Conditions requires each supplier to comply with, among other things, the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, all other applicable Anti-Bribery Laws, the UK Modern Slavery Act 2015, and the California Transparency in Supply Chains Act of 2010. ETC does not actively certify supplier compliance with its Purchase Order Terms and Conditions, but reserves the right to do so.

IV.            Internal Accountability
ETC does not presently have anti-slavery and human trafficking standards internally or externally, or associated accountability standards and procedures for employees or suppliers.

V.            Training
ETC does not currently provide training to its employees or suppliers who have direct responsibility for supply chain management on human trafficking and slavery.

ETC reserves the right to conduct assessments, audit suppliers, develop standards, or require training related to human rights, human trafficking, slavery, or supply chain transparency.