CALIFORNIA TRANSPARENCY ACT
ABOUT THIS STATEMENT
This statement is published in accordance with the California Transparency in Supply Chains Act (California Civil Code Section 1714.43).
XPEL and its affiliated companies (collectively “XPEL”) are committed to honesty, integrity, and fair dealing in our business activities. This commitment includes the fair and equitable treatment of employees, third-party business partners and their employees, and all other stakeholders with whom we engage. XPEL does not tolerate human rights abuses in any of its direct or indirect business activities.
XPEL'S BUSINESS AND STRUCTURE
XPEL is a global provider of automotive products, including automotive surface and paint protection, headlight protection, and automotive window films. In addition, our product offerings include architectural window film (both commercial and residential) and security film protection for commercial and residential uses.
XPEL is incorporated in Nevada and headquartered in San Antonio, Texas. We also have offices or operations in various other countries, including, the Netherlands, the United Kingdom, Canada, Mexico, Taiwan, and Germany.
XPEL’s Code of Business Conduct and Ethics requires all personnel to uphold the highest levels of business ethics and personal integrity in all business transactions and interactions. This includes compliance with all applicable laws, rules, and regulations, and the responsibility to maintain a safe, healthy, and respectful work environment. All employees are expected to comply with the Code of Conduct and are provided with training and/or communications explaining their responsibility to act ethically and in compliance with the law.
The California Transparency in Supply Chains Act requires a company to address five disclosure categories: verification, audit, certification, internal accountability, and training. XPEL responds to each as follows:
- Verification. XPEL’s supply chains are based throughout the world and include (1) suppliers of direct materials including thermoplastic polyurethane (TPU), manufacturing materials and packing materials, (2) suppliers of indirect goods and services including professional services, facilities, office supplies, and sales and marketing services, (3) distributors, (4) franchisees, and (5) installers. Before engaging any supplier, distributor, installer, or any other entity in our supply chain, XPEL reviews the third-party. This review may include some or all of the following: reference checks, internet searches, verification of applicable licenses and certifications, and financial reviews.
In addition, XPEL informally monitors its supply chain to evaluate risks including the risk of human trafficking and slavery. This informal monitoring is conducted internally by XPEL and not by a third-party.
- Audit. XPEL’s standard supplier agreements permit it to conduct site inspections and audits under certain circumstances. However, XPEL has not performed any supplier audits to evaluate compliance with standards for trafficking and slavery in supply chains.
- Certification. XPEL’s standard supplier agreement requires suppliers to continuously certify and warrant that the supplier “and its subcontractors are in compliance and will continue to comply with any and all applicable federal, state, provincial and local law, regulations, executive orders, codes, ordinances, applicable industry standards, Supplier and customer’s corporate policies, procedures, and policies and other rules of law relating to the performance, manufacturing, delivery and operation of any Orders and the provision of Supplies . . .”. This includes complying with all applicable “labor standards and safety laws”.
- Internal Accountability. XPEL does not currently maintain any documented accountability standards or procedures that pertain directly to slavery and human trafficking.
- Training. XPEL does not currently provide human trafficking and slavery training for its employees or management with supply chain responsibilities.
Going forward, XPEL will continue to review and update its policies and procedures, as well as expand its compliance and ethics program with respect to preventing slavery and human trafficking.