Axon Supplier Code of Conduct

Axon’s mission is to enhance public safety through our advanced suite of smart weapons, cameras and software. We take this responsibility very seriously, and hold ourselves and the suppliers we work with to the highest standards of quality and reliability. Simply put - our products cannot fail!

Underlying these standards are fundamental values to which we hold ourselves accountable:

• Human Rights

• Health and Safety

• Supplier Diversity

• Sustainability

• Ethics/Anti-Corruption

• Material Compliance

• Business Continuity

We encourage, and candidly expect, our supplier partners and their extended supply chains to embrace these values as their own and provide transparency with respect to both current operations and future plans as it relates to these initiatives.

Human Rights

Axon values respect for human life both as part of our mission and our core values.

Suppliers are expected to employ or otherwise engage workers who meet the minimum applicable legal age requirements and may not use or engage in any indentured or forced labor, slavery, human trafficking or compulsory labor either within their operations or their own extended supply chain. Wages and benefits should be competitive, but at a minimum meet the requirements of local labor laws.

We embrace and encourage a diverse workforce including all ages, genders, gender identity or expression, races, religions, disability and sexual orientation and encourage this value within our suppliers.

Health and Safety

Axon places high priority on protecting the health and safety of all employees and people who enter our global facilities. It is Axon’s expectation that our suppliers embrace the same spirit to ensure the following:

• A safe and respectful work environment for all employees and visitors to their operations

• Employees and visitors are provided appropriate personal protective equipment (PPE)

• Operators and/or equipment have appropriate shields and barriers to prevent injury

• An appropriate preventative maintenance program is in place to ensure ongoing safety of any equipment

• Employees are provided the highest level of training to perform their jobs successfully and safely

Supplier Diversity

Axon embraces the collaboration that comes from engaging with a diverse supply base and seeks to find ways to grow in this important category. We encourage suppliers of minority or women-owned businesses to make their capabilities known to us as we actively seek out partnerships with suppliers who share our commitment to a diverse workforce.

Sustainability

The ability to limit pollution of our environment and reuse/recycle components or equipment that have reached the end of their useful life is viewed as a strategic advantage in our supply base. Axon encourages suppliers to focus on sustainability in their operations and provide us with ideas on how we can continue to most optimally manage this within our own operations relating to their supplied products and services.

Ethics/Anti-Corruption

Axon strives to maintain the highest level of ethical standards in all of our commercial relationships. Honesty and integrity are foremost in our business approaches and provide a basis for continued relationship growth. Participation in any bribery or corruption activity is wholly unacceptable and will result in the immediate termination of any and all agreements between Axon and supplier firms.

By extension Axon does not tolerate any form of slavery or indentured servitude relating to a supplier’s workforce and, if found, will result in immediate termination of our relationship.

Material Compliance

All suppliers are expected to comply with regulations relating to Conflict Minerals, REACH, RoHS, CalProp 65 and others as required. Statements of certification to be provided upon request and it is understood that the extended supply chains also adhere to these regulations as required.

Business Continuity

Suppliers are encouraged to develop and maintain plans for continuity or redundancy in its operations including safety stocks. This activity should be designed to ensure Axon’s ability to maintain continuity of supply in the event of an interruption in any or all of supplier’s operations.

To help ensure adherence to the above, Axon is committed to the following five steps which assist in achieving transparency in our Supply Chain:

• Verification of Product Supply Chains
  All production facilities manufacturing Axon supplied goods for which Axon is the importer of record must become registered before Axon accepts goods produced there. In the future, as part of our efforts to verify our suppliers’ compliance with Axon’s standards and applicable laws, each of those production facilities will be required to complete a human rights and compliance questionnaire as part of the registration process and authorize unannounced compliance audits.
  In addition to our standard audit process, Axon assesses workforce demographic risks. Where appropriate, we deploy auditors with deep subject matter expertise to conduct a supplemental assessment specific to foreign contract workers and supplier recruitment practices. This supplemental assessment includes reviewing hiring practices, interviewing labor agencies, analyzing migrant worker conditions, auditing living accommodations and generally understanding the employment experience at a given facility.

• Supplier Audits
  Axon, or our qualified third-party auditors may, in the future, conduct mostly unannounced facility audits at registered facilities to verify our suppliers’ compliance with Axon’s standards, and with an emphasis on any facility deemed to be “higher-risk”. We may also regularly conduct product safety and quality assurance audits as well as CTPAT supply chain security audits (as part of the Customs and Trade Partnership Against Terrorism program) at our suppliers’ facilities. Quality/safety and security auditors are trained to spot potential social compliance concerns (including indicators of forced labor) and to escalate them for further investigation by our internal and independent 3rd party investigators.

• Certification of Compliance with Laws
  As an additional condition of doing business with Axon, all our suppliers will warrant that the products they supply to Axon are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. Axon’s standards will expressly prohibit our suppliers from utilizing any forced or compulsory labor and accordingly, we expect our suppliers to remediate indicators when identified. Axon will not do business with a vendor that fails to warrant compliance with all applicable laws and will discontinue doing business with a supplier who fails to live up to that promise. This expectation extends not only to our suppliers’ own operations and production facilities, but to their upstream material and component suppliers as well.

• Accountability
  Axon will continue to partner with reputable experts and adopt proven methods to help discover and eradicate forced labor from our supply chain. If forced labor indicators are found in a supplier’s production facility, we will work quickly to assess the situation and evaluate a variety of factors including the supplier’s and facility’s ability to remediate, the feasibility of providing meaningful remedy to impacted workers and the likelihood of sustained improvement. When remediation is achievable, the supplier is required to work with the facility, in consultation with Axon and industry experts, to develop and implement an appropriate corrective action program in keeping with our ‘do no harm’ aspiration. If the situation is not conducive to remediation, then we will work to disengage responsibly from a facility. Axon will also make an Integrity Hotline available to Axon team members, our suppliers and the workers in our suppliers’ production facilities. The purpose of the Integrity Hotline is to provide a vehicle for anonymously reporting concerns dealing with potentially unfair, unlawful or unethical business practices and to maintain a system through which Axon can investigate claims and address complaints.

• Axon Team Member and Supplier Training
  Axon will administer mandatory training for team members responsible for sourcing decisions on an array of topics, including Axon’s standards. We will also require all team members to comply with our  Business Conduct Guide, which includes an annual review of Axon’s standards.
  
  By upholding these key values and standards in our business practices and supplier relationships, we can continue to provide our customers and community stakeholders with lifesaving technologies, developed in an ethical fashion.