UEI’s Disclosure under the California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California, like Universal Electronics Inc. (UEI), to disclose efforts to eradicate slavery and human trafficking from its direct supply chain to tangible goods offered for sale. The following is disclosure under the Act for UEI and its subsidiaries:

1. Risk Assessment/Verification. UEI has periodically assessed risks associated with its supply chain, including that of its subsidiaries and business units. While UEI’s supply chain is linked globally, UEI believes that the countries in which its suppliers are predominantly located and the vast majority of items, components, and parts supplied for its products present minimum levels of risk of slavery and human trafficking. This belief is based in part on information contained in the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor issued on October 1, 2013. Because of this low risk, UEI has not employed a third party for verification.

2. Auditing. Because UEI does not believe the risk in its supply chain to be significant, UEI has not audited its suppliers for compliance. To the extent this belief changes, UEI will consider stronger measures such as auditing or third party verification for any suppliers that it determines to present higher risk.

3. Supplier Agreement. UEI has periodically assessed risks associated with its supply chain and considers there to be a low risk that its suppliers, either knowingly or inadvertently, engage in the practices of slavery or human trafficking.  To the extent this belief changes, UEI will consider measures such as requiring certifications from any suppliers that it determines to present higher risk.

4. Internal Accountability Standards For Employees. Since the Company was founded, UEI’s business practices have been governed by integrity, honesty, fair dealing and full compliance with all applicable laws. UEI requires its employees to review the company’s Code of Conduct and sign a Code of Conduct Acknowledgment Form annually, and provides periodic ethics training to its employees.

5. Procurement Training. UEI has periodically assessed risks associated with its supply chain and considers the risk that its suppliers engage in the practices of slavery and human trafficking to be low.  Because UEI does not believe the risk in its supply chain to be significant, UEI has not undertaken formal training programs for slavery and human trafficking issues. To the extent this belief changes, UEI will consider developing relevant training programs for employees responsible for procurement.