Anti-Slavery and Human Trafficking Statement

Introduction

The United Kingdom (UK) Modern Slavery Act was established in October 2015 and introduced a requirement for large commercial organizations operating in or conducting business within the UK to publish a statement setting out the steps to be taken during the year to ensure slavery and human trafficking is not taking place in their business or in any of their supply chains.

Organization

NAC International is a U.S.-based global leader in providing nuclear fuel management technology solutions, nuclear fuel transport services, and fuel cycle consulting, and is a wholly owned subsidiary of Hitachi Zosen Corporation. NAC’s offices are based in the United States; however, we have a material sales presence across Europe. As such, we have created an Anti-Slavery and Human Trafficking Statement to ensure compliance the UK Modern Slavery Act of 2015.

Our Supply Chain

Our supply chains include, but are not limited to, fabricators, contractors, operational support services, and suppliers.

Our Policies and Due Diligence Processes for Slavery and Human Trafficking Prevention

Modern slavery and human trafficking are crimes and violations of fundamental human rights. NAC International is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing policies intended to ensure such activities are not taking place anywhere in our business.

We have a zero-tolerance policy for slavery and human trafficking occurring within our own business and our supply chain. As an employer of predominantly professionally qualified and highly skilled workers providing nuclear engineering related services, the risk of these activities occurring within our business or supply chain is low. Nevertheless, NAC will take steps to identify and assess the risks in relation to slavery and human trafficking within our business and supply chain.

Next Steps

This is our inaugural year for adapting an anti-slavery and human trafficking policy statement and we intend to adopt internal policies and procedures to ensure employee awareness of and compliance with our zero-tolerance position on modern slavery and human trafficking. This includes training on steps employees can take to prevent NAC from inadvertently engaging in supplier relationships in conflict with this policy statement.

As part of our initiative to identify and mitigate risk, we will identify potential risk areas when taking on new suppliers and regularly review our existing supply chains. We will also develop processes to mitigate the risk of slavery and human trafficking occurring in our supply chains as well as monitor potential risk areas in our supply chains.

Further, as part of our contracting process, where appropriate, we will communicate our expectations to our suppliers to comply with all applicable laws, including those combatting modern slavery and human trafficking, such as the Modern Slavery Act of 2015 (UK).