2026 Australian Modern Slavery Act Transparency Statement

This modern slavery statement is made pursuant to the Modern Slavery Act of 2018 (Cth), for the financial year ending 31 December 2025. It sets out the steps that we have undertaken, and are continuing to take, to ensure that modern slavery and human trafficking are not taking place within our business operations or supply chains.

OUR COMPANY

This statement has been prepared by Guardian Industries Nong Khae Co., Ltd (Registration No. 0195550001011) as the reporting entity under the Modern Slavery Act 2018 (Cth). Guardian Industries Nong Khae Co., Ltd, which operates under the Guardian Glass brand, is incorporated in Thailand, and its registered office is located at 42 Moo 7 Nongplamoh Sub-District, Nongkhae, Saraburi, 18140, Thailand. Guardian Industries Nong Khae Co., Ltd has a subsidiary, Guardian Industries Rayong Co., Ltd (Registration No. 0105538090182) located in Thailand, which is also covered by this statement. Both entities are part of the Koch Inc. group of companies and share common policies and processes relevant to modern slavery and human trafficking. For clarity, in this statement, “Guardian Glass”, “we”, “our” or “its” refer to Guardian Industries Nong Khae Co., Ltd and its subsidiary, Guardian Industries Rayong Co., Ltd.

Guardian Glass is one of the world’s largest manufacturers of float, coated and fabricated glass products. At its 22 float lines around the globe, Guardian Glass produces high performance glass for use in exterior (both commercial and residential) and interior architectural applications, as well as transportation and technical products. Guardian Glass products can be found in homes, offices, cars and some of the world’s most iconic architectural landmarks. The Guardian Technology & Development (GTD) Team continuously works to create new glass products and solutions using the most advanced technology to help customers see what’s possible. Visit guardianglass.com.

Guardian Glass’s global organizations, no matter where we do business, are committed to conducting all business lawfully—with stewardship and integrity. This commitment extends throughout our business and supply chain and includes, among other things, an expectation that our suppliers do not use modern slavery, in any of its forms, including human trafficking, to produce the products and services they provide to Guardian Glass. Our supply chains, which demonstrate our shared commitment, are a key part of our continued success. Guardian Glass’s compliance and ethics expectations are set out in our Code of Conduct (https://codeofconduct.kochinc.com/). Guardian Glass also leverages its supplier contract templates, which include a statement by which suppliers certify that their business and supply chain are maintained in a lawful and socially responsible way including, among other things, that neither human trafficking nor slavery or forced labor takes place in any part of their business, and that they do not use slavery or forced labor in any of its forms, including human trafficking. The contract templates are used with all new suppliers to Guardian Glass. Due to the elevated level of sophistication that is required to produce the goods and services that Guardian Glass uses to make its float, coated and fabricated glass products, there is a low probability that any form of modern slavery would be utilized in our industry.

OUR VALUES & THE KOCH STEWARDSHIP FRAMEWORK

Koch companies subscribe to a management framework, Principle Based Management™, that is based on proven principles of human progress and a deep appreciation for the dignity of every individual. Our focus on individuals and bottom-up solutions rather than top-down imperatives is evident in our Stewardship Framework and drives our approach to Environmental, Social, and Corporate Governance (ESG).

From our Stewardship Framework:

At Koch, stewardship encompasses the responsible management of our actions and the resources entrusted to our care in a manner that respects the rights of others. By “rights” we mean everyone’s right to their own life, liberty, and property, and equal treatment under the law.

CODE OF CONDUCT

With specific regard to the need to combat human trafficking and modern slavery in all of its forms, the “Lawful Employment” section of the Code of Conduct states:

Commitment to Lawful Employment Practices

We are committed to adhering to applicable employment and labor laws everywhere we operate. This includes observing those laws that pertain to child labor, forced labor, human trafficking, wages, working hours, and freedom of association. In addition to other expectations, our commitment to social responsibility specifically includes the following:

Child Labor - Guardian Glass will not employ child labor. What constitutes child labor is defined by applicable child labor laws, or where such laws are not in place, employees will not be permitted to work in a position where they are younger than the minimum local legal age for employment in that particular job. Guardian Glass will adhere to all applicable laws and regulations which govern employment terms and conditions for minors. Minor is defined as an individual who is under the age of adulthood as defined by applicable law.

Forced Labor - Guardian Glass prohibits the use of forced labor, human trafficking, or involuntary prison labor. Recruiting and selection activities are conducted in compliance with applicable law and any applicable collective bargaining obligations.

Wages and Work Hours - Guardian Glass is committed to meeting all minimum wage obligations and collective bargaining agreements regarding maximum hours, minimum wage, overtime work and the payment of overtime compensation.

Guardian Glass will:

• Conduct recruitment honestly and with integrity, which means avoiding any misleading or fraudulent actions and working only with recruiters who comply with the local labor laws of the country(ies) where recruitment takes place. Additionally, Guardian Glass will not require employees or applicants to pay fees for their employment and will bear the cost of recruitment activities mandated by Guardian Glass, such as pre-employment background checks.
• Ensure that employees always have access to their identity or immigration documents and that these are never withheld in any way.

EMPLOYEE TRAINING

Every employee has the responsibility to:

• Always act in accordance with applicable laws, our Code of Conduct, Our Values, and other company standards, policies, procedures, practices, guidelines, and work rules.
• Avoid any activity that might have the appearance of being illegal or unethical.
• Seek a full understanding of compliance requirements, risks, and key controls that apply to your role. No one is expected to know every policy or standard word for word, but should understand the policies and standards that apply to their role.
• Seek assistance from the many resources that are available to them, if they have questions.
• Promptly report potential or actual violations of a law, company policy or standard, or any request to violate a law, company policy or standard.
• Promptly report any issue that they believe has not been appropriately resolved, even if it means raising it with another available resource.
• Cooperate completely and honestly with company investigations.

During the reporting period, Guardian Glass implemented the commitments outlined in its Code of Conduct throughout its operations through its myLearning (virtual training) platform and ad hoc trainings and communications. All employees at Guardian Glass are required to complete Code of Conduct training, which includes content on lawful employment practices, within 60 days of joining and at regular intervals determined by Guardian Glass. 

If Guardian Glass were to become aware of a potential risk of modern slavery within our operations, we would investigate the matter and if confirmed, take immediate action to implement corrective actions to end such practices.

RISKS OF MODERN SLAVERY

Guardian Glass recognizes that risks of modern slavery and human trafficking may arise within its operations and supply chains, although such risks are considered low. These risks reflect the potential for Guardian Glass to cause, contribute to, or be directly linked to modern slavery through our manufacturing activities, employment practices and relationships with suppliers, distributors, agents and contractors. Our assessment of modern slavery risk focuses on risks to people, including workers in our operations and supply chains, rather than solely on risks to our business. To understand the primary risks that may be present in the operations and supply chains of Guardian Glass, we undertake activities such as engaging with workers and other stakeholders, visiting suppliers, partnering with our legal and compliance & ethics capabilities to review contract agreements. 

Within its operations, risks may arise in connection with hiring of our employees or the use of contractors, and subcontractors performing work on behalf of Guardian Glass. These arrangements may present risks where third parties do not adhere to applicable labor standards and laws. 

Within its supply chains, Guardian Glass sources a range of products such as raw materials, chemicals and energy used in the glass making process and facility-related services such as maintenance, as well as technical and professional services from suppliers, distributors, and agents. While Guardian Glass has a global supply chain, its primary raw materials are largely sourced locally from the Asia-Pacific region. Some raw materials are sourced from other regions such as North America if not available locally. Some of these third parties may operate in jurisdictions where labor standards and enforcement may vary. Risks may arise where suppliers or their own supply chains do not meet applicable labor and human rights expectations set forth by Guardian Glass.

OUR SUPPLY CHAINS & THEIR ADHERENCE TO OUR VALUES

We expect all those in our supply chain to comply with our values. Therefore, non-compliance with applicable laws, regulations, and our standards regarding modern slavery and human trafficking will result in corrective action up to and including termination, depending on the circumstances. Modern slavery, in any form, has an exceptionally low probability of being utilized in Guardian Glass’s supply chain, thus creating a minimal risk profile. Guardian Glass assesses and selects its suppliers with care. We maintain the expectations outlined in our Code of Conduct for lawful and respectful business practices and extend this expectation to our suppliers, who are assessed under a risk-based review that could include, but is not limited to, activities such as supplier screening and site visits.

These expectations are also outlined in our Terms & Conditions for direct and indirect suppliers (https://www.guardian.com/us/en/supplier-portal). If a supplier has not complied with our standards, guidelines and Terms & Conditions were to arise, depending on the circumstances, we follow a staged remediation process, which involves investigating the matter, requiring the supplier to provide information and establish corrective actions, requiring the supplier to report on the implementation of the agreed corrective action plans and if issues are not resolved, we would consider terminating the relationship. Review of such non-conformance is undertaken on a case-by-case analysis, given the surrounding information.

ASSESSING THE EFFECTIVENESS OF ACTIONS

Guardian Glass assesses the effectiveness of its actions in its operations and supply chains through its existing compliance and ethics processes.

These processes include:

• Monitoring and reviewing the nature and number of concerns reported through the Compliance & Ethics GuideLine or similar reporting mechanisms;
• Tracking outcomes of complaints, for example, complaints that were resolved or resulted in corrective action being taken;
• Reviewing trends in grievances and reported concerns over time to identify recurring issues or emerging risk areas;
• Monitoring completion rates for relevant compliance and Code of Conduct training, including modules covering lawful employment practices;
• Investigating reported concerns; and
• Implementing corrective actions where appropriate and following up to confirm that agreed actions have been completed and are effective.

These processes support Guardian Glass’s efforts to identify and respond to potential issues within its operations and supply chains and to understand whether its actions are working as intended. We regularly review these indicators and outcomes through our compliance processes and, where we identify gaps or recurring issues, we adjust and strengthen our actions to continually improve their effectiveness.

CONSULTATION PROCESS

In preparing this statement, Guardian Glass consulted internally with relevant functions involved in its operations and supply chain activities, including procurement, ESG, and legal and used their input to develop the final statement.

APPROVAL

This statement is made pursuant to the Australian Modern Slavery Act of 2018 (Cth) and constitutes our modern slavery statement for the financial year ending 31 December 2025. It is approved by the Governing Board and signed by a director.

William Jeffrey Petek, Director

Guardian Industries Nong Khae Co., Ltd.