Anti-Human Trafficking Statement

Rockwell Collins Anti-Human Trafficking Corporate Statement

Fiscal Year 2017

This statement is made pursuant to Part 6 of the Modern Slavery Act

Rockwell Collins Inc.

Rockwell Collins is a pioneer in the design, production and support of innovative solutions in aerospace and defense. Our expertise in flight deck avionics, cabin electronics, mission communications, information management, and simulation & training is strengthened by a global service & support network that spans 27 countries. Working together, our global team shares a vision to create the most trusted source of communication and aviation electronics solutions. Our supplier relationships are governed by a continuum of integrated events/processes that begin with the identification of a supplier or source to supply a component, product, subassembly or service. These relationships are characterized by innovation, collaboration, integration, performance and continuous improvement. If and when our suppliers do not work together with us to continuously improve performance, integrate their business processes, etc., they are held accountable.

Slavery & Human Trafficking Policies

Rockwell Collins is committed to ensuring that we uphold fundamental human rights. We believe that all human beings should be treated with dignity, fairness and respect. Our company will only engage suppliers and agents who demonstrate a serious commitment to the health and safety of their workers, and operate in compliance with human rights laws and regulations. This means that Rockwell Collins: does not use child or slave labor or engage in human trafficking; denounces any degrading treatment of individuals or unsafe working conditions; and prohibits its suppliers and agents from using child or slave labor or engaging in human trafficking. Rockwell Collins expects our suppliers and contractors to educate their employees on prohibited activities, to discipline employees found to have violated laws and to notify Rockwell Collins with any credible information they have regarding a potential violation of human rights laws and regulations.

Due Diligence Process

Rockwell Collins recognizes due diligence can help to identify human trafficking. Rockwell Collins has implemented a process to identify suppliers that are high risk for trafficking violations and reviews new suppliers to determine risk. Suppliers identified as high risk complete a supplier assessment, developed using industry anti-human trafficking resources.  This assessment provides a more in-depth look at internal practices which may identify trafficking concerns. Additional investigation is conducted as needed. Rockwell Collins supplier agreements and documentation make very clear the requirement that suppliers comply with anti-human trafficking laws.

Risk Assessment

Rockwell Collins sources electronics and electrical products, an industry that has been identified as high risk for trafficking by industry anti-human trafficking resources. Suppliers who provide these products in high-risk countries are given a supplier assessment. Based on responses, Rockwell Collins evaluates the need for further investigation.

Measures of Effectiveness

Rockwell Collins strives to ensure that trafficking is not taking place in its business or supply chain. In order to be effective, Rockwell Collins captures the following metrics: 1) number of potential violations reported to the Ombudsman Office, 2) number of suppliers who are identified as high risk, 3) portion of total Rockwell Collins spend that is high risk, 4) number of suppliers who have had violations, and 5) number of aerospace & defense peers who have had violations in their supply chains. These metrics are gathered regularly and communicated internally to ensure there is awareness of potential trafficking violations and to take appropriate additional actions when warranted.

Training

Rockwell Collins provides training and communication to ensure employees and suppliers are aware of anti-human trafficking requirements. Procurement agents are required to complete the anti-human trafficking section of the Procurement Documentation training prior to being awarded delegation of authority. Additionally, Rockwell Collins distributes annual communications to employees through the Supply Chain Community of Practice and in an internal news article. Suppliers receive an annual communication on anti-human trafficking. Rockwell Collins' policy statement on human trafficking is discussed in the Standards of Business Conduct, which is available to employees, suppliers and on the company's website.


Rockwell Collins Anti-Human Trafficking Corporate Statement

Fiscal Year 2017

This statement is made pursuant to the California Civil Code 1714.43

Rockwell Collins is a pioneer in the design, production and support of innovative solutions in aerospace and defense. Our expertise in flight deck avionics, cabin electronics, mission communications, information management, and simulation & training is strengthened by a global service & support network that spans 27 countries. Working together, our global team shares a vision to create the most trusted source of communication and aviation electronics solutions. Our supplier relationships are governed by a continuum of integrated events/processes that begin with the identification of a supplier or source to supply a component, product, subassembly or service. These relationships are characterized by innovation, collaboration, integration, performance and continuous improvement. If and when our suppliers do not work together with us to continuously improve performance, integrate their business processes, etc., they are held accountable.

Rockwell Collins is committed to ensuring that we uphold basic fundamental human rights. We believe that all human beings should be treated with dignity, fairness and respect. Our company will only engage suppliers and agents who demonstrate a serious commitment to the health and safety of their workers and operate in compliance with human rights laws and regulations. This means that Rockwell Collins: does not use child or slave labor or engage in human trafficking; denounces any degrading treatment of individuals or unsafe working conditions; and prohibits its suppliers and agents form using child or slave labor or engaging in human trafficking. Rockwell Collins expects our suppliers and contractors to educate their employees on prohibited activities, to discipline employees found to have violated laws and to notify Rockwell Collins with any credible information they have regarding a potential violation of human rights laws and regulations.

Rockwell Collins has created a process to evaluate and address risks of human trafficking and slavery. Suppliers who are identified as high risk are given a supplier assessment, developed using industry anti-human trafficking resources. This assessment provides a more in-depth look at internal practices, which may identify trafficking concerns. Additional investigation is conducted as needed. Rockwell Collins supplier agreements and documentation make very clear the requirement that suppliers comply with anti-human trafficking laws.

Rockwell Collins reviews and assesses suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. This review is conducted by Rockwell Collins employees.   

Rockwell Collins requires suppliers comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business. 

Rockwell Collins maintains an internal policy and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. 

To ensure employees and suppliers are aware of anti-human trafficking requirements, Rockwell Collins provides training and communications. Procurement personnel are required to complete the anti-human trafficking section of the Procurement Documentation training prior to being awarded delegation of authority. Additionally, Rockwell Collins distributes annual communications to employees. A communication on anti-human trafficking is also  sent to suppliers on an annual basis. Rockwell Collins' policy statement on human trafficking is discussed in the Standards of Business Conduct, which is available to employees, suppliers and on the company's website.

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