California Transparency in Supply Chains Act of 2010


California’s Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts taken to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale thereby giving consumers more information to make buying decisions. Ingersoll-Rand has a policy of not doing business with companies who use forced, bonded, indentured or slave labor.

Ingersoll-Rand's selection for suppliers includes the review of the supplier's track record of compliance. Ingersoll-Rand expects suppliers to conduct their relationship with the company consistent with the Ingersoll-Rand Code of Conduct and the Ingersoll-Rand Business Partner Code of Conduct, which prohibits the use of forced, bonded, indentured or slave labor.

Supplier audits are conducted for any number of reasons including qualifications of new suppliers. Ingersoll-Rand's supplier audit guidelines include the review of the supplier's practices relating to use of forced, bonded, indentured or slave labor. Ingersoll-Rand generally does not use a third party for verification or to conduct unannounced audits of its supply chain.

On an annual basis, Ingersoll Rand surveys a sampling from the top 80% of direct material suppliers to confirm their adherence to our Business Partner Code of Conduct. As part of that survey, Ingersoll Rand specifically requests that suppliers certify that they and the materials incorporated into the products they sell comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. The survey also asks the supplier to certify that they do not use forced, bonded, indentured or slave labor. These requests for certification are also part of the supplier onboarding process.

We educate our procurement and quality personnel to identify and report violations. In addition, violations may be reported by anyone to Ingersoll Rand's Ethics HelpLine at 1-855-IR-ETHICS. Ethics HelpLine telephone numbers for locations outside of the United States may be found in Ingersoll Rand’s Code of Conduct.

Violations may also be reported via email to ethics@irco.com. Ingersoll-Rand provides annual training to team members on Ingersoll Rand’s Code of Conduct. Team members also may report violations of the Code of Conduct through the reporting channels described above.

Employees who violate the Code of Conduct may be subject to disciplinary action up to and including termination of employment (as consistent with applicable law). See the Ingersoll Rand Code of Conduct for more information. And again, as to contractors, Ingersoll-Rand has a policy of not doing business with companies who use forced, bonded, indentured or slave labor.

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