Compliance

California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act requires Panavision® to disclose its efforts to eliminate the use of slavery and human trafficking from its supply chain. Panavision values integrity and transparency in the conduct of its business and is committed to responsible social and ethical business practices, including treating people with respect and dignity. These values have been established in Panavision’s Code of Business Conduct as well as its policies, procedures, and business practices.

Panavision has developed specific internal accountability standards and procedures for employees and suppliers regarding slavery and human trafficking. For example, Panavision requires its suppliers to comply with the Panavision Supplier Code of Conduct (link). Panavision’s Standard Purchase Order Terms and Conditions (link) also outline our right to audit our suppliers to evaluate compliance with our Supplier Code of Conduct and other government laws and regulations. If we determine that a particular supplier is not in compliance with our Supplier Code of Conduct or applicable government laws and regulations, Panavision has the ability to terminate its business relationship with that supplier. Additionally, Panavision provides company employees who have direct responsibility for supply chain management with informal training on our Supplier Code of Conduct. Employees are expected to act proactively, raising concerns about ethical issues and violations of our Code of Business Conduct, our Supplier Code of Conduct, and governmental rules and regulations. Employees who are aware or become aware of violations of our internal policies and/or laws and regulations must immediately bring it to the attention of their supervisors, the General Counsel of the Company, or the Corporate Compliance Officer. Panavision’s confidential telefax and email are available to all employees and directors to enable the reporting of any noncompliance with our policy. Panavision employees who do not act promptly to report noncompliance matters may be subject to disciplinary action up to and including termination.