Corporate Sustainability

Here are just some of the ways we ensure that our business is not conducted at the expense of the environment:

• We continually improve our environmental management system to enhance performance
• We hold our facility managers responsible and accountable for ensuring proper chemical handling and processing, maintaining healthy air and water quality, monitoring water consumption, managing resources sustainably, reducing waste, and controlling greenhouse gas emissions
• Our team members receive ongoing training and communication in all matters of environmental protection and regulation
• Top level managers make sure that our facilities are operating within environmental compliance parameters
• We regularly monitor greenhouse gas emissions, energy expenditure, waste management, climate risk, and water management/wastewater processing
• We adjust our business as needed to make sure that our products continue to meet increasing demand for more environmentally friendly electric and hybrid vehicles
• We make sure that our production processes embrace circularity and support recycling by considering end-of-life for all products and materials

Report on Fighting Against Forced Labor and Child
Labor in Supply Chains Act
Identifying Information
This report outlines Global Steering Systems’ (GSS) supply chain program for the entity doing
business in Canada: Global Steering Systems, LLC located in Watertown, Connecticut, USA.
This is the first submission of this report and covers activities from January 1, 2023 through
December 31, 2023. At this time, GSS does not have similar reporting obligations in other
jurisdictions. The referenced entity is categorized as manufacturing within the automotive
industry and operates within the United States.
GSS is a leading manufacturer of steering components for automotive original equipment
manufacturers like Stellantis, Ford Motor Company, Jeep, Lucid Motors, RIVIAN, and General
Motors, to name a few. With a decades-long track record of excellence and production
capabilities in North America, Asia Pacific, and Europe, GSS designs and manufactures
“must-have” products for ensuring driver safety and satisfaction the world over—now and in
the years ahead. GSS is an independent, privately held company with operations in the
United States, China, and Poland.
GSS offers a safe and supportive environment that encourages growth, innovation,
dedication, and the pursuit of excellence. We also understand and support the importance
and strength of a blended, culturally diverse workforce, where all perspectives are welcomed
and all team members are respected and included. Our team members come from different
backgrounds who contribute unique perspectives and talents, resulting in comprehensive
solutions to satisfy global automotive demands.
Steps Taken Through 2023
As part of the hiring process, we verify the identity and age of potential team members are
screened to ensure adherence to relevant regulations and laws. As outlined in the GSS
terms and conditions, our hiring and labor practices are aligned with the United States labor
law, The Fair Labor Standards Act of 1938, as amended, and regulations and orders issued
by the United States Department of Labor and there under. This Act establishes standards
and employer obligations to protect employee rights, including the right to a minimum wage
and overtime pay limits to working hours and prohibits the employment of minors in
oppressive labor.

GSS structure:
GSS is a private, limited liability company. Executive Leadership made up of the Chief
Executive Officer, Chief Financial Officer and Vice President of Sales & Marketing, Vice
President of Operations serves as the governing body. The topics covered in this report are
also be managed by the Vice President of Purchasing and the Human Resources Manager.
Functional area leadership is included in decision-making when relevant.
GSS activities:
Our location in Watertown, Connecticut manufactures intermediate steering components for
the automotive industry. GSS components serve the passenger car, SUV and light truck
markets, and we also offer specialty steering products for the commercial truck, delivery
vehicle and agricultural markets.
GSS Supply Chain, Policies and Due Diligence
As a global company, the GSS supply chain network is global. GSS and its suppliers must
adhere to strict customer and industry standards. Suppliers are responsible for adhering to
all requirements, as outlined in the Supplier Quality Manual and Terms and Conditions. GSS
does not exclude suppliers from requirements based on location, product or material – each
supplier is treated in a similar manner. Relevant requirements within the manual include:

• Compliance to GSS Customer Specific Requirements – Suppliers of material and
  services to GSS are required to comply with all applicable end user, OEM customer
  specific requirements. We’ve recently seen a shift in customer-specific specifications
  in the automotive industry to begin including sustainability-related requirements.
  These requirements often include clauses related to prohibiting human rights
  violations such as forced and child labor. GSS consistently works to improve the
  quality system to adhere to customer-specific requirements.
• Conflict Minerals – Suppliers are required to disclose via annual reporting whether
  the products they supply to GSS contain “conflict minerals necessary for the
  functionality or production” of these products. The Conflict Minerals Reporting
  Template (CMRT), published by the Responsible Minerals Initiative, collects
  information through the supply chain regarding mineral country of origin and
  smelters and refineries being used. This provides a screening mechanism for forced
  and child labor and other human rights abuses. To date, GSS has not identified nonconforming smelters or refineries on its CMRT.
• Government Statutory and Regulatory Compliance – GSS complies with all applicable
  laws, government regulations and rules in the countries in which it operates. GSS
  suppliers shall also comply with all applicable governmental regulations in countries
  in which they operate. Suppliers should recognize and comply with applicable
  government regulations including those in the country of manufacture as well the
  country receiving the products and the final country of sale.
• Health, Safety and Ethics – GSS prioritizes health, safety and ethics. It is expected
  that suppliers will comply with the expectations listed:
  o Provide safe working conditions for all employees, customers and contractors.
  o Adhere to all applicable National, Regional, State and Local laws and
  regulations governing environment, health, safety and ethics.
  o Extend and communicate these expectations to suppliers.
  
  In addition to these requirements, GSS is ISO 9001:2015/IATF 16949:2016 certified. The
  certification involves demonstration of:
• Adherence to customer specific requirements.
• Corrective action procedure for GSS activities and the activities of its suppliers.
• Internal audit program.

The information in this report shows the existence of strong supplier relationships and an
excellent foundation. Our activities through 2023 set the stage for GSS to begin 2024 with
the development and implementation of a robust supplier sustainability program that
includes risk management and due diligence activities related to forced and child labor. Our
2024 report will outline these improvements.

Attestation
In accordance with the requirements of the Act, and in particular section 11 thereof, I attest
that I have reviewed the information contained in the report for the entity or entities listed
above. Based on my knowledge, and having exercised reasonable diligence, I attest that the
information in the report is true, accurate and complete in all material respects for the
purposes of the Act, for the reporting year listed above.

Full name: Chris Fenton
Title: President, Global Steering Systems
Date: May 31, 2024