Modern Slavery Policy

This is the Modern Slavery and Human Trafficking Statement of the Company for the financial year ended December 31, 2020. During the year ended 31 December 2020 the Company was divested from the Bombardier Inc. (“Bombardier”) group of companies and was acquired into the Spirit AeroSystems Inc. (“Spirit”) group of companies. This transaction completed on 30 October 2020 and, as such, this statement by the Company will cover the period 1 January 2020 to 30 October 2020 under Bombardier ownership and the period 31 October 2020 to 31 December 2020 under Spirit ownership.

The Company is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. This same commitment is shared by Bombardier and Spirit.

As stated within both Bombardier’s and Spirit’s Codes of Conduct, Bombardier and Spirit have a zero tolerance for the use of child labour, forced labour or human trafficking practices. Neither Bombardier nor Spirit will knowingly do business with any subcontractors, business partner, supplier, or other third parties who violate this policy.

Spirit advises every employee to immediately report any concerns relating to child labour, forced labour, or human trafficking practices to their manager or the Corporate Compliance department.

About Bombardier

Bombardier is a global leader in aviation, creating innovative and game-changing planes. Our products and services provide world-class experiences that set new standards in passenger comfort, energy efficiency, reliability, and safety.

About Spirit

Spirit is a global organisation and is one of the largest independent non-OEM aircraft parts designers and manufactures in the aerostructures sector. For the two months from 1 November 2020 and ended December 31, 2020, Spirit generated net revenues of $88.2 million from the Company in Belfast, Northern Ireland. For the twelve months ended December 31, 2020, Spirit had net income of $(25.7) million from the Company in Belfast, Northern Ireland. Spirit is the wholly owned subsidiary of Spirit AeroSystems Holdings, Inc. and is the parent company of Spirit AeroSystems International Holdings, Inc. of which the Company is a subsidiary. Spirit has business operations in the United States, Scotland, Northern Ireland, Morocco, France and Malaysia. The Company employs 2,763 employees in Belfast, Northern Ireland.

In order to fulfil the needs of the Company’s customers, which includes Airbus, to design and manufacture aerostructures, we work with a range of suppliers across the globe. The Company works closely with and has developed positive relationships with our key suppliers. Due to the nature of our business and the strict compliance requirements we are subject to, we already engage fully with our suppliers to ensure that they can demonstrate compliance. We have a stable supply base that we work with regularly and have an expanded depth and knowledge of their business. If we engage new suppliers, we have a detailed process to audit their facilities prior to receiving orders. We operate within a very heavily regulated industry that requires the approval of suppliers not only by the Company but by its customers.

We consider that our sector is low risk due to the skilled nature of our workforce. However, we carry out on-site audits of all of our major suppliers (and have a number of different policies that are aligned with our obligations under the Modern Slavery Act 2015 in the UK, including a Code Conduct and Human Trafficking Policy).

Bombardier’s code of Ethics (“the Code”) addresses ethical conduct in our work environment, business practices and relationships with external stakeholders.

The Code applies at all times, without exception, to all members of the Bombardier Board of Directors, all management and all employees. You can see the code here: https://www.bombardier.com/en/governance/code-of-ethics.html.

In line with Bombardier’s vision for its suppliers, Bombardier actively engages its supply chain by the adherence of its suppliers to its Supplier Code of Conduct. The Supplier Code of Conduct details Bombardier’s expectation of suppliers in respect of human rights, legal compliance, health and safety, the environment, anti-corruption, ethics and governance. You can see the code here: https://www.bombardier.com/en/governance/supplier-code-of-conduct.html.

Bombardier’s Supplier Code of Conduct specifically includes provisions prohibiting child labour and forced or compulsory labour, as follows:

“Child Labour

Bombardier will not engage in nor support the use of child labour and will not tolerate the use of child labour by its Suppliers either. For the purpose of this Supplier Code, child labour covers all type of work carried by employees under the age of 15 years old, excluding when such employment forms the basis of vocational training or takes form of educational program. However, for employment or work which by its nature or circumstances is not suitable for a person under the age of 18 years old, child labour shall mean employees under the age of 18 years old.

Forced Labour / Modern Slavery / Human Trafficking

Bombardier will not engage in the use of forced or enslaved labour or human trafficking, nor will it tolerate their use at any level in its supply chains. Suppliers must not demand any work or service from any person under the menace of any penalty. For example, Suppliers’ employees must be free to leave work or terminate their employment with reasonable notice, and they are not required to surrender any government issued identification, passports or work permits as a condition of employment.”

As part of Spirit’s commitment to combating modern slavery, it has in place an organisation wide general Anti-Slavery/Trafficking Policy, as well as, a UK specific anti-slavery procedure, Modern Slavery Procedure.

Spirit also has a number of policies and procedures designed to comply with other global requirements and, where possible, will develop organisation wide policies and procedures (or adapt these) to ensure that appropriate and coordinated action is taken throughout the organisation.

The following organisation wide policies and/or procedures are relevant to Spirit’s commitment to tackle modern slavery and human trafficking:

• Code of Conduct
• Human Trafficking Policy and Procedure
• Ethical Business Conduct Procedure
• Conflict Mineral Policy
• Conflict Minerals Reporting Process

Spirit firmly believes in respecting others and this means supporting human rights. Spirit has a zero tolerance for the use of child labour, forced labour or human trafficking practices. Spirit will not knowingly employ or do business with subcontractors, business partners, suppliers, or other third parties who violate this policy.

Spirit also makes suppliers aware of applicable policies and requires them to adhere to the same high standards. Spirit has also created a Supplier Code of Conduct incorporating language concerning human rights, which apply to all suppliers. You can see the code here: https://s23.q4cdn.com/405433451/files/doc_governance/Supplier-Code-of-Conduct.pdf

For a number of years, the Company has incorporated the Bombardier Supplier Code of Conduct into its contracts with suppliers. Under Spirit ownership we are adopting Spirit’s equivalent Supplier Code of Conduct. When supplier contracts are being updated, we are changing the Bombardier Supplier Code of Conduct to the Spirit Supplier Code of Contract. This work will continue over the year.

We also evaluate our procurement processes to ensure that we are undertaking appropriate due diligence at the outset of any new relationship with a supplier.

These processes have been developed by Spirit’s and the Company’s compliance, supply chain and legal teams.

The Company continued to develop and deploy a number of complementary measures to guard against the risk of forced and child labour in supply chains. Those measures include the following:

• We have continued to use our processes to reduce risks in our supply chain in 2020. Our supply chain organization has utilised its risk assessment procedure (formalised last year) prior to engaging with new suppliers and conducts reviews based on their operational risk framework.
• Should employees or suppliers have concerns regarding slavery they have the responsibility to report their suspicions and we provide multiple channels for them to do so on a confidential basis.
• Supplier self-assessments of risk continue to be undertaken via questionnaire. Suppliers are asked to confirm that they (and their supply chains) comply with our expectations and recognised Corporate Social Responsibility standards, including with respect to human rights. Suppliers are required to complete or have completed the questionnaire to our satisfaction before a contract is issued for signature.

As part of the Company’s efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we try to carry out on site audits of all of our key suppliers on an annual basis. These on-site audits involve, as a minimum, a site tour. We will incorporate factors related to these issues as part of that onsite process for the Company’s suppliers. During the year to 31 December 2020, on-site audits have been limited due to COVID-19 restrictions, but the Company will continue its efforts perform on-site audits during the coming year.

As part of a wider Spirit exercise, we issued a survey in 2021 to the Company’s suppliers and will re-issue in the future for consistency. We will develop a means to identify gaps and create a plan based on a risk assessment.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains
• monitor potential risk areas in our business and supply chains
• reduce the risk of slavery and human trafficking occurring in our business and supply chains
• provide adequate protection for whistleblowers

The Company will regularly evaluate the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by conducting the risk management activities narrated in the Modern Slavery Procedure.

We do not consider that we operate in a high-risk sector due to the skilled nature of our workforce. We will, however, assess geographical risks as we accept that exposure may be greater depending on the geographical location and will take into account the Freedom House categorisation and the Transparency International Corruption Perception Index (CPI).

Where we have identified a potential risk through our risk assessment procedures, we will explore ways of remedying and mitigating these risks through due diligence, improved procurement practices or industry collaboration.

We ensure all our suppliers adhere to our policy prohibiting slavery. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure to comply with our policy prohibiting these types of acts, we will seek to terminate our relationship with the relevant supplier.

The effectiveness of our policies and procedures will be kept continually under review in order to ensure that these are robust enough to identify any issues.

Spirit mandated training on this subject as appropriate and has and will continue to invest in educating staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees will be encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees will be taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Following the Company’s review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the further steps narrated above to tackle slavery and human trafficking. This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year commencing 1 January 2020 and ending 31 December 2020.

Modern Slavery Statement - Short Brothers plc - to 31 December 2020