The California Transparency in Supply Chains Act requires certain retailers and manufacturers doing business in California to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains.

Turtle Beach Corporation, and its affiliates and subsidiaries, expects that the manufacturers we contract with, and their vendors and suppliers, will comply with all applicable international, national and local laws, rules, regulations and standards, including with respect to human rights and labor rights.

Verification

We are committed to fair labor practices within our supply chain. We require all manufacturing partners to review and acknowledge our Manufacturer Code of Conduct before they join our supply chain and whenever renewing their relationship with us. Our Manufacturer Code of Conduct requires our manufacturing partners to, among other things:

1. 1. Comply with all anti-human trafficking, forced labor, and modern slavery laws and rules;
2. 2. Not engage in any acts which could be considered to constitute modern slavery;
3. 3. Take steps to ensure that there is no modern slavery in their own supply chain; and
4. 4. Respect internationally recognized human rights.

Risks related to slavery and human trafficking are evaluated by our internal supply chain team and, in certain cases, via third parties by our customers.

Audits

Our team routinely visits our manufacturing partner’s facilities. Further, our manufacturing contracts and our Manufacturer Code of Conduct allow us or an independent auditor to audit and investigate compliance with our standards for risks related to human trafficking and slavery in supply chains. Such audits may be unannounced.

Certification

Our manufacturing partners contractually represent and warrant compliance with applicable laws, including the laws of the United States and other countries in which they do business. These warranties include compliance with all applicable human trafficking, slavery, servitude, and forced or compulsory labor laws. In addition, our manufacturers are required to ensure their vendors and suppliers of materials incorporated into our products do not engage in any such acts.

Internal Accountability

Our Code of Business Conduct and Ethics, to which all internal team members are subject, requires that our business be operated in an ethical manner and in compliance with all applicable laws, including laws against human trafficking and forced labor. Further, under the Company’s Whistle Blower Policy, if employees, officers, or directors become aware of a violation of any law, rule or regulation, whether by an internal party or somebody doing business on our behalf, that individual must promptly report the matter to their manager and our Human Resources Department. If a manager receives a report of a violation of our Code of Business Conduct and Ethics, they must immediately inform our Chief Executive Officer.

Failure to comply with the standards outlined in our Code of Business Conduct and Ethics will result in disciplinary action including, but not limited to, reprimands, warnings, probation, or suspension without pay, demotions, reductions in salary, discharge, and restitution. Certain violations may be referred to appropriate governmental or regulatory authorities for investigation or prosecution. Moreover, any manager who directs or approves of any conduct in violation of the code, or who has knowledge of such conduct and does not immediately report it, also will be subject to disciplinary action, up to and including discharge.

Training

Our employees and managers who have responsibility for supply chain management will receive training published by the U.S. International Trade Administration with respect to mitigating forced labor risks in global supply chains.