California Transparency in Supply Chain Act

California’s Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts taken to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale thereby giving consumers more information to make buying decisions. Trane Technologies has a policy of not doing business with companies who use forced, bonded, indentured or slave labor.

Trane Technologies' selection for suppliers includes the review of the supplier's track record of compliance. Trane Technologies expects suppliers to conduct their relationship with the company consistent with the Trane Technologies Code of Conduct and the Trane Technologies Business Partner Code of Conduct, which prohibits the use of forced, bonded, indentured or slave labor.

Supplier audits are conducted for any number of reasons including qualifications of new suppliers. Trane Technologies' supplier audit guidelines include the review of the supplier's practices relating to use of forced, bonded, indentured or slave labor. Trane Technologies generally does not use a third party for verification or to conduct unannounced audits of its supply chain.

On an annual basis, Trane Technologies surveys a sampling from the top 80% of direct material suppliers to confirm their adherence to our Business Partner Code of Conduct. As part of that survey, Trane Technologies specifically requests that suppliers certify that they and the materials incorporated into the products they sell comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. The survey also asks the supplier to certify that they do not use forced, bonded, indentured or slave labor. These requests for certification are also part of the supplier onboarding process.

We educate our procurement and quality personnel to identify and report violations. In addition, violations may be reported by anyone to Trane Technologies' Ethics HelpLine.

Violations may also be reported via email to ethics@tranetechnologies.com. Trane Technologies provides annual training to team members on Trane Technologies' Code of Conduct. Team members also may report violations of the Code of Conduct through the reporting channels described above.

Employees who violate the Code of Conduct may be subject to disciplinary action up to and including termination of employment (as consistent with applicable law). See the Trane Technologies Code of Conduct for more information. And again, as to contractors, Trane Technologies has a policy of not doing business with companies who use forced, bonded, indentured or slave labor.