Transparency in Supply Chains Act of 2010 Statement

Headway is committed to responsible sourcing, including the elimination of human trafficking and slavery, if any, in our supply chain. As a member of the TDK Group, Headway complies with the TDK Code of Conduct* requirements to respect human rights and discharge its social responsibility with a strong sense of ethical values for the purpose of creating a sustainable society. The TDK Group Policy on Human Rights** commits the TDK Group to undertake efforts to promote respect for human rights, including asking business partners to take appropriate measures to fulfill their responsibility to respect human rights. The TDK Group Statement Regarding Respect for Human Rights sets forth TDK’s Approach***, to promote the correct understanding, awareness, and improvement of human rights issues, not only in business activities within the TDK Group itself, but also in the value chain.

Internal Accountability and Training. We require our employees, contingent workforce and temporary employees to comply with the TDK Code of Conduct. All TDK Group members must follow all applicable laws, regulations, rules and international norms concerning human rights, including child labor and forced labor. We train all employees on the standards incorporated in the TDK Code of Conduct and TDK’s efforts regarding Corporate Social Responsibility, including issues of human rights, among them, forced labor and human trafficking.

Certification of Direct Suppliers. We expect all of our suppliers to comply with all applicable laws, including, but not limited to, those addressing the eradication of forced, bonded, indentured, involuntary convict or compulsory labor or illegal child labor. All Headway suppliers are expected to adopt sound human rights practices and to treat workers fairly and with dignity and respect, provide a safe and healthy work environment for their workers, and conduct business in compliance with applicable environmental, employment, all other applicable laws and regulations. To this end, Headway Purchase Order Terms and Conditions specifically state:

COMPLIANCE WITH LAWS:

Evaluation, Verification, and Audit. We conduct surveys of our suppliers as necessary in accordance with the norms of the Responsible Business Alliance (RBA), among them, to evaluate and address risks of human trafficking and slavery, and adherence to employment laws and environmental standards. Headway reserves the right to conduct audits of its suppliers, based on the information obtained in its supplier evaluations.