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UK Modern Slavery Act


Waters Corporation (“The Company”) takes the issue of slavery and human trafficking seriously and has a zero-tolerance approach to the issue. As of this writing, Waters has received neither indication nor confirmation of the presence of slavey, child labor, or forced labor amongst our direct or approved base of suppliers. Waters Corporation operates through its subsidiaries Micromass UK Limited and Waters Limited in United Kingdom.

Micromass primarily supports the design, manufacture and sale of mass spectrometry instruments, and accompanying software, chemicals, and spare parts. Waters Limited conducts sales, support, and marketing of analytical instruments, associated chemicals, and software for customers in the United Kingdom.

To support ongoing compliance with the requirements of the Modern Slavery Act 2015, Waters also conducts the following activities:

Risk Assessments: We periodically conduct global supply chain risk assessments, sometimes with the support of third-party consultants, to explore emerging issues including human rights. When doing such assessments, we consider four key factors that drive the risk of forced labor in our supply chains: sector and industry risks, product-specific risks, geographic risks, and company-specific risks.

Supplier Expectations: Waters values fair, reliable business relationships with suppliers and partners, and encourage those with whom we do business to share in our vision of responsible and ethical business practices. We expect our suppliers to adhere to all applicable laws, rules, and regulations of the countries in which they operate. It is critical that our suppliers uphold the human rights of workers and treat them with dignity and respect while ensuring a safe and healthy working environment.

Supplier Terms & Conditions: Our expectations are communicated to suppliers as part of our supplier onboarding process and are included in the standard terms and conditions of our purchasing contracts. Waters reserves the right to discontinue business relationships with suppliers that fail to operate in a legal, responsible, and ethical manner.

Prohibition of Child and Forced Labor: We work with our suppliers to ensure that local laws regarding wages, working conditions, and working hours are observed, and to ensure that child or forced labor is not used in the manufacture of our products or in the components they contain.

Conflict Minerals: Our Conflict Minerals program has dedicated staff and works to ensure ongoing compliance with the Dodd-Frank Conflict Minerals Rule. We annually conduct a review of our supply chain for components that contain gold, tin, tungsten, or tantalum (3TG), and work to ensure that that 3TG in Waters products does not originate from sources that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country.

Monitoring and Management: As part of our supplier management process, suppliers may be
required to demonstrate conformance with our requirements. New suppliers, dependent on their
classification, undergo a qualification process that includes an assessment audit designed to evaluate
the supplier’s capabilities with regards to ensuring ethical and responsible business practices. Existing
suppliers’ ongoing performance is evaluated on a periodic basis. Our Global Trade and Corporate
Compliance functions evaluate all new business partners against sanctioned party lists and
reputational risk screening databases.

Whistleblowing and Non-Retaliation: Waters maintains an email inbox for reporting violations of
applicable laws, regulations, and policies. Waters takes its commitment to compliance very seriously
and expects all Company Parties and third-party business partners to share in that commitment. The
Company, therefore, requires Company Parties and third-party business partners to promptly report
actual or suspected violations of applicable law or any Company policy. Parties providing information
through these channels in good faith will not be subject to any retaliation.

Continuous Improvement: We consistently seek to foster good practice and enhanced controls
across the business. Part of this effort includes establishing practical and meaningful key performance
indicators to measure progress against our goals. We periodically benchmark our supply chain risk
management policies and procedures against those of relevant customers, competitors, comparator
firms, and industry groups to ensure that we are following consensus best practices.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and is applicable to Waters’
financial year ending 31 December 2020.


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[This statement was last updated on 12 April 2021]