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Modern Slavery (Anti-Slavery and Human Trafficking) Policy

Policy Overview

Hyosung and the United States Government prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.”

Hyosung is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy includes forced labor and unlawful child labor. Hyosung will not tolerate or condone human trafficking or slavery in any part of our global organization.

Hyosung employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners, and others through whom Hyosung conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.


This policy applies to all personnel employed by or engaged to provide services to Hyosung, included, but not limited to, employees, officers, and temporary employees of Nautilus Hyosung America, Inc., and Hyosung’s U.S. and international subsidiaries, and independent contractors (for ease of reference throughout this policy, “employees”).

Every employee is responsible for reading, understanding, and complying with this policy. Hyosung managers are responsible for ensuring that employees who report to them directly, or indirectly, comply with this policy and complete any certification or training required of them. If you have any questions or concerns relating to this policy, consult the Hyosung legal department or human resources department.


Report any conduct that you believe to be a violation of this policy to Hyosung’s legal or human resources department. Reports may also be made through the Hyosung Ethics Hotline at 844-990-0002 or via the internet at the following website: http://www.lighthouse-services.com which allows anonymous reporting as permitted by applicable law.

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

Disciplinary Actions

Hyosung will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

Any violation of this policy may be grounds for disciplinary action, up to and including termination. Hyosung and its subsidiaries have the exclusive right to interpret this policy regarding their respective employees.

Violation of the U.S. Government’s policy against human trafficking may also result in criminal prosecution of responsible individuals.

Summary of U.S. Government Policy of Prohibiting Trafficking in Persons

U.S. Government policy prohibits trafficking in persons and slavery. Government contractors and their employees, subcontractors, subcontractor employees, and agents must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons.

• Procuring commercial sex acts.

• Using forced labor in the performance of any work.

• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority. • Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, basic information; or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing, and associated costs (if provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work.

• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.

• Charging applicants recruitment fees.

• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment.

• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards.

• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing with legally required information and in a language the employee understands.

Compliance with this Policy

Employees must ensure that they read, understand and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager OR the legal and human resources as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or the legal or human resources department as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the legal or human resources department.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Hyosung is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform human resources immediately.

Communication and Awareness of this Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in termination for misconduct or gross misconduct. Hyosung may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.