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California Transparency in Supply Chains Act & UK Modern Slavery Act Statement

For the fiscal year ended December 31, 2018

Panavision and its subsidiaries (including Light Iron, Panalux, Lee Filters, Direct Digital and Island Studios) are among the best-known and well-respected companies globally as providers of production and post-production products and services to the entertainment industry. We value integrity and transparency in the conduct of our business, and we are committed to responsible social and ethical business practices, including respect for human rights. These values have been established in Panavision’s Code of Business Conduct. This statement explains the steps that Panavision and all of its subsidiaries have taken to eliminate slavery and human trafficking from our supply chain as required by The California Transparency in Supply Chains Act and the UK Modern Slavery Act.

Panavision is a worldwide camera and production equipment rental and post production services company; therefore, our supply chain is global and complex. We require our suppliers to comply with the Panavision Supplier Code of Conduct (link) which prohibits our suppliers from using forced, bonded, indentured, prison or child labor. In addition, Panavision’s Standard Purchase Order Terms and Conditions (link) requires suppliers to comply with all applicable laws and regulations in furnishing goods and services to Panavision, including those regarding slavery and human trafficking of the countries in which Panavision does business, and allows Panavision to audit suppliers to determine compliance with the Panavision Supplier Code of Conduct and applicable law. If it is determined that a supplier is not in compliance with the Panavision Supplier Code of Conduct or applicable laws, Panavision has the ability to terminate our business relationship with that supplier. Panavision is commencing a review of suppliers in high-risk areas and developing a program of certification and verification, but currently does not contemplate utilizing third parties to conduct independent and unannounced audits or verifications.

Additionally, Panavision provides employees who have direct responsibility for supply chain management with informal training on our Supplier Code of Conduct which prohibits our suppliers from using forced, bonded, indentured, prison or child labor. Panavision employees are expected to act proactively, raising concerns about ethical issues and violations of our Code of Business Conduct or applicable laws and regulations. Employees who are aware of violations of the Code of Business Conduct or applicable laws and regulations must immediately bring it to the attention of their supervisors, human resources, the General Counsel or the Corporate Compliance Officer. Employees who do not act promptly to report noncompliance matters may be subject to disciplinary action up to and including termination.

 

Panavision’s audit committee of the Board of Directors, which is responsible for compliance matters, approved this statement on April 22, 2019.

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