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Statement on Slavery & Human Trafficking

About this Statement

This statement is published in accordance with the UK Modern Slavery Act 2015. This statement covers slavery, servitude, forced or compulsory labor, and human trafficking.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Introduction

XPEL and its affiliated companies (collectively “XPEL”) are committed to honesty, integrity, and fair dealing in our business activities. This commitment includes the fair and equitable treatment of employees, third-party business partners and their employees, and all other stakeholders with whom we engage.

XPEL does not tolerate human rights abuses in any of its direct or indirect business activities. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsoryor trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

XPEL’s Business and Structure

XPEL is a global provider of automotive products, including automotive surface and paint protection, headlight protection, and automotive window films. In addition, our product offerings include architectural window film (both commercial and residential) and security film protection for commercial and residential uses. XPEL is incorporated in Nevada and headquartered in San Antonio, Texas. We also have offices or operations in various other countries including, the Netherlands, the United Kingdom, Canada, Mexico, Taiwan, and Germany.

About This Policy

The purpose of this policy is to:

a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and

b) provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners.

This policy does not form part of any employee's contract of employment, and we may amend it at any time.

Your Responsibilities And How To Raise A Concern

You must ensure that you 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 as soon as possible if you believe or suspect that a breach of 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 that a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy 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. 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.

We are 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 unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately.

Relevant Policies

XPEL’s Code of Business Conduct and Ethics requires all personnel to uphold the highest levels of business ethics and personal integrity in all business transactions and interactions. This includes compliance with all applicable laws, rules, and regulations, and the responsibility to maintain a safe, healthy, and respectful work environment.

All employees are expected to comply with the Code of Conduct and are provided with training and/or communications explaining their responsibility to act ethically and in compliance with the law.

XPEL’s Supply Chain

XPEL’s supply chains are based throughout the world and include:• suppliers of direct materials including thermoplastic polyurethane (TPU), manufacturing materials and packing materials;

  • suppliers of indirect goods and services including professional services, facilities, office supplies, and sales and marketing services;
  • distributors;
  • franchisees; and
  • installers.

Before engaging any supplier, distributor, installer, or any other entity in our supply chain, XPEL reviews the third-party. This review may include some or all of the following: reference checks, internet searches, verification of applicable licenses and certifications, and financial reviews.

Breaches of this policy

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

Next Steps

Going forward, XPEL will continue to review and update its policies and procedures, as well as expand its compliance and ethics program with respect to preventing modern slavery.