California Transparency in Supply Chains Act of 2010 - Corporate Disclosure

Policy on Slavery and Human Trafficking

Aethercomm, Inc. is dedicated to conducting business in a lawful and ethical manner. It is our expectation that our suppliers also conduct themselves in such a manner. Pursuant to its obligations as a government contractor under FAR sec 22.1700 et seq., Aethercomm has adopted a zero-tolerance policy regarding slavery and trafficking in persons. All Aethercomm employees, contractors, subcontractors, vendors, and suppliers, and employees or agents thereof, are prohibited from engaging in any form of slavery or human trafficking, including but not limited to:

  1. Engaging in trafficking of persons as defined by: the laws of the United States; the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children; and all other applicable laws;
  2. Engaging in severe forms of trafficking in persons, as defined by Section 22.1702 of the Federal Acquisition Regulation;
  3. Procuring commercial sex acts, as defined by Section 22.1702 of the Federal Acquisition Regulation;
  4. Using forced labor, as defined in Section 22.1702 of the Federal Acquisition Regulation.

Any Employee who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will be terminated. Likewise, any contractor, subcontractor, supplier, or vendor who violates this policy, or who willfully, knowingly or negligently allows subordinates to do the same, will have their respective contracts terminated. Suspected violations will be reported to the appropriate law enforcement agency.

All Aethercomm employees, vendors, and direct suppliers are notified of this policy and the consequences of violating it. Aethercomm requires all vendors and direct suppliers to certify that materials incorporated into their products comply with applicable laws regarding slavery and human trafficking in the countries where they are doing business. Aethercomm further requires all vendors and direct suppliers to comply with FAR Section 52.222-50 “Combating Trafficking in Persons.” Aethercomm does not conduct independent audits of supply chains as enforcement of the Federal Acquisition Regulation falls under the jurisdiction of the U.S. Government.

Aethercomm does not have a training program in human trafficking mitigation at this time. However, Aethercomm is currently looking into creating and implementing a training program by 2013.