Elliott Group (Elliott), headquartered in Jeannette, Pennsylvania, USA, is committed to conducting business with honesty, integrity, and transparency wherever we operate around the world; to always act legally and ethically; and to accord all persons the dignity and respect to which they are inherently entitled.

Elliott enjoys an excellent reputation earned by generations of dedicated employees over more than 100 years. Our reputation is built as much upon our integrity as upon the quality of our products and services. Elliott's customers trust us to do what is right. This trust is our most valuable asset.

VERIFICATION: Elliott purchases raw materials and components from suppliers located in the United states and in countries around the world. To do business with Elliott, a supplier must agree to abide by the principles spelled out in Elliott's Supplier Handbook and those set forth in the Elliott Group Code of Conduct. These principles include compliance with all applicable laws, regulations, and treaties, both domestic and foreign, and respect for international principles of human rights.

Elliott maintains a list of preferred suppliers and conducts due diligence on all suppliers before they are qualified. Potential suppliers are provided with a copy of the Supplier Handbook as part of the supplier qualification process, and must verify in writing that they have read it. Elliott also mandates that eah of its suppliers read, understand, and fully comply with the Code of Conduct and The Path of Integrity: A Guide to the Elliott Group Code of Conduct. Finally, Elliott's Purchase Order Terms and Conditions (Terms & Conditions) reference the Supplier Handbook and the Code of Conduct, requiring an affirmative commitment from suppliers as contractual reinforcement of Elliott's principles and expectations.

Elliott embraces the fact that nationality, gender, race, age, and ecconomic status are irrelevant to the fundamental standard of equal treatment to which all people are entitled. We do not tolerate violations of these inalienable human rights.

AUDIT: Elliott's supply contracts permit us to audit preferred supplier compliance with certain contract terms. While these terms do not currently include an intentional focus on human trafficking, child labor, or slavery, Elliott has reserved the right to investigate instances of non-compliance with the principles set forth in our Supplier Handbook, Code of Conduct, and Purchase Order Terms and Conditions. These principles include international principles of human rights. Evidence of non-compliance would be considered a breach of contract, and is grounds for contract termination.

Elliott works actively with our suppliers to deny any advantage through our material procurement to armed groups engaged in human rights abuses. We hold our suppliers to the same high level of integrity as we hold ourselves.

CERTIFICATION: Elliott requires its preferred suppliers to strictly comply with all applicable laws, regulations, sanctions, trade embargoes, and other requirements of all duly constituted governmental authorities (national, provincial, municipal, local, or other governmental agency) in the countries in which they operate. Other than our contractual obligations with our preferred suppliers, spelled out in Elliott's Code of Conduct, Supplier Handbook, and Terms & Conditions, and the reservation of our right to investigate instances of non-compliance, Elliott does not have a formal supplier certification process.

Elliott is committed to fair and ethical business practices. We do not permit or engage in unethical or illegal dealings of any sort.

INTERNAL ACCOUNTABILITY: Just as Elliott employees are held accountable under the terms of their employment to conduct Elliott business in an ethical manner, our preferred suppliers are also held accountable for conducting business with or for us in an ethical manner. Under the terms of their contract, they are required to follow all laws of the countries in which they operate, and the principles specified in the Elliott Code of Conduct, Supplier Handbook, and Terms & Conditions. Failure to comply with the law, or to timely address contractual non-compliance, is grounds for contract termination.

Elliott participates only in transactions that are compatible with legal and accepted social standards.

TRAINING: Elliott periodically trains its employees, including our global supply chain and sourcing managers and employees, on the standards defined in the Code of Conduct, including ethical behavior and expectations, policies, procedures, and legal requirements that provide the framework for our business conduct.

Elliott requires its employees to do more than simply follow the rules and obey the law. We expect them to always do the right thing. At the most basic level, our actions should be guided by our moral compass; always do what is right, what is ethical, and what is moral.

Elliott Group Disclosure Statement