Statement on Human Trafficking and Slavery
Standard Motor Products, Inc. explicitly forbids the use of human trafficking, forced labor, unlawful child labor and slavery in the manufacture, distribution and sale of products, and we will not tolerate the use of such practices by those with whom we conduct business. The following statements disclose our efforts to evaluate and address the risks of such practices in our supply chain and throughout our business, in accordance with the California Transparency in Supply Chains Act and the United Kingdom Modern Slavery Act of 2015. Though the requirements of the UK Modern Slavery Act must still be fully defined, Standard Motor Products, Inc. supports the progress it makes towards eliminating modern slavery.
Verification. Inherent in our values and our commitment to good corporate citizenship is a respect for human rights and ethical labor practices, which are irreconcilable with human trafficking and slavery. Our Code of Ethics and operating procedures adopted under our Code are designed to ensure our compliance with all applicable laws, rules and regulations, and the recognition of human rights and ethical labor practices in all aspects of our business. Our efforts to manage the risks of our direct suppliers engaging in human trafficking and slavery primarily consist of communicating our commitment to ethical labor practices to these suppliers and establishing and maintaining mutually beneficial, long-term relationships with suppliers who demonstrate a commitment to such practices. We do not engage third parties to assist us in these efforts.
Audit. We do not currently conduct audits of our direct suppliers to evaluate their compliance with our Code of Ethics. However, if we determine that a particular supplier should be evaluated more closely, we will seek to assess and implement reasonable and appropriate measures to mitigate any identified risks, including by conducting independent and/or unannounced audits of the supplier to evaluate their compliance with these requirements.
Certification. In the ordinary course of business, we require our direct suppliers to agree to comply with all applicable laws, rules and regulations, including those prohibiting human trafficking and slavery. However, we do not currently require our direct suppliers to certify that materials incorporated into products supplied to us specifically comply with laws regarding human trafficking and slavery in the country(s) in which they are doing business. As discussed above, if we determine that a particular supplier should be evaluated more closely, we may require the supplier to make such a certification if we determine the measure to be reasonable and appropriate to mitigate the identified risks.
Accountability. All of our employees are responsible for adhering to our Code of Ethics. As discussed more fully under the heading “Verification” above, the practices of human trafficking and slavery would constitute a violation of our Code and would result in disciplinary action being taken against any employee found to have engaged in such practices, up to and including termination of employment. We have also established several reporting channels for our employees, customers and suppliers, and any other interested persons, to report actions that they perceive to be unlawful, unethical or in violation of our policies. For additional details on our reporting channels, please refer to the section captioned “Reporting Concerns” in our Code of Ethics, available at www.smpcorp.com under “Investor Relations—Governance Documents—Code of Ethics”.
Training. We develop and train our employees on policies that are designed to ensure that we operate our business in compliance with all applicable laws, rules and regulations. These training sessions include our employees who are responsible for managing our relationships with our suppliers, and we require that they adhere to our policies in their dealings with suppliers.