There is no updated 2022 statement. The 2021 statement does not sufficiently address this question.

p.3: Employee and Supplier Codes of Conduct

p.3: "In addition, our publicly posted Policy Against Modern Slavery defines modern slavery, gives a concrete list of prohibited actions, and provides reporting channels for suspected instances of modern slavery. We strive to hold ouremployees and suppliers to high standards. Any violation of our standards by an employee can result indisciplinary action, including termination of employment. Any violation by a supplier or member of ourextended workforce can result in contract or engagement termination.Contracts with suppliers include language requiring compliance with our Supplier Code of Conduct, whichprohibits the use of any form of modern slavery. We also include more extensive anti-modern-slavery contractual language in some supplier contracts."

OCI exercises oversight over the Supplier Responsibility and Extended Workforce Solutions teams. Suchoversight includes the collection of quarterly program performance and risk metrics, as well as reviews ofsupplier risk assessments, due diligence questions, and audit protocols that relate to modern slavery riskindicators. Any potential policy and process improvements to the Supplier Responsibility program arepresented to the Supplier Responsibility Steering Team for approval. Once approved, the SupplierResponsibility team works with our suppliers to communicate our expectations and request evidence ofadherence to our standards.

restrict prohibited fees and penalties