As a manufacturer doing business in the state of California, California State law requires us to provide disclosure regarding our efforts to address the issue of slave labor and human trafficking in our supply chain.

ECM Industries LLC is committed to the termination of any human trafficking and slavery from its supply chain. Suppliers are prohibited from using child, forced, or prison labor, and must provide a work environment free from physical punishment. Rates of pay must comply with the national laws of the countries in which the suppliers do business. Employee work hours must be limited to those authorized by applicable laws including being properly compensated for overtime. Suppliers must respect the right of workers to freely associate and organize. The suppliers of ECM Industries LLC are not permitted to use bonded laborers. Suppliers' employees must be free to leave manufacturing facilities and not subject to unreasonable restrictions on their movements. Suppliers' employees must be free to terminate their employment at will.

ECM Industries LLC trains its managers and employees that work directly with suppliers concerning these standards and verification of compliance by suppliers. While no written certification of compliance is currently required from our suppliers, supplier compliance is monitored through unscheduled, on-site visits and audits. These visits and audits are conducted personally by ECM Industries LLC auditing teams and include confidential employee interviews of individuals selected by ECM Industries LLC. The visits and audits are announced to the suppliers with only as much lead time as necessary to ensure that required documentation is available for the auditing team. These on-site visits and audits can include verification of time and pay records. Deficiencies found during supplier visits and audits can result in penalties, ranging from requiring corrective action plans and follow up audits, to termination of the business relationship.