Corporate Responsibility

COMMUNITY
At Comtech, we do business in over 40 countries around the world to serve our customers in their communities. Comtech’s mission is to be the leading global technology company providing terrestrial and wireless network solutions, next-generation 9-1-1 emergency services, satellite and space communications technologies, and cloud native capabilities to commercial and government customers around the world. Our unique culture of innovation and employee empowerment unleashes a relentless passion for customer success.

ORGANIZATIONAL GOVERNANCE
We are committed to conducting our business in ways that are principled, transparent, and accountable. The foundation of these commitments is expressed in our Standards of Business Conduct, which require not only legal compliance, but also broader commitments to address ethical business practices, diversity and inclusion, and human rights. A copy of the Standards of Business Conduct is maintained on our website at www.comtech.com, under the link “Investor Relations.”

MINORITY AND DIVERSE CANDIDATE OUTREACH
With employees and contractors spanning the world, we endeavor to build a diverse workforce to better support our global customer base. We actively recruit minorities, the disabled and veterans. We hire our employees based on their individual skills, qualifications, and experience, treating them with respect and dignity. We have also implemented diversity in hiring at the highest levels of Comtech’s leadership, both on our Board of Directors and in our executive management. We have refreshed and diversified our Board with the appointment of four women and two African-Americans within the past several years. Two of the female directors each chairs a Board Committee. Within the ranks of our executive management, a number of women have assumed leadership roles as Chief Operating Officer, Chief People Officer, Chief Growth Officer, General Counsel and Treasurer. We believe in everyone taking responsibility for, and working together to contribute to, Comtech’s success, which is tied to cultivating, fostering, and advancing a culture of equity and inclusion.

TOGETHER
Although we are deemed an essential business by the U.S. government, for the safety of our employees, customers, partners, suppliers, and directors, due to the COVID-19 pandemic, we have implemented remote working arrangements, curtailed most business travel, and established social distancing safeguards at our facilities. We strove to accommodate and support employees quarantining, recovering from COVID-19, or caring for family members recovering. We are also committed to providing a fair and harassment-free working environment. We expect that all relationships among persons in the workplace will be businesslike and free of unlawful bias, prejudice, and harassment. It is our policy to promote equal employment opportunities without discrimination or harassment on the basis of race, color, national origin, religion, sex, age, disability, or any other status protected by law. We prohibit and will not tolerate any such discrimination or harassment.

ENVIRONMENTAL AWARENESS
As part of our sustainable business model, environmental responsibility is a focus for Comtech. We incorporate environmentally sound business practices and an efficient use of materials across our technological innovation and manufacturing operations and foster environmental awareness among our employees, customers, suppliers, and other key stakeholders to help protect our planet. We believe we have a successful track record of maintaining compliance with the various global environmental standards and initiatives that are applicable to our business segments, including with the respect to the quantities of waste and emissions generated at certain such facilities. We are committed to responsible use of the earth’s natural resources, and we strive to minimize any impact on climate change.

CARING
We take responsibility for how our products impact communities. As an essential provider of critical wireless communication and location-based solutions to the U.S. government, the emergency 911 community and Mobile Network Operators (“MNOs”) around the world, good citizenship, data security and compliance with laws are priorities for the Company. We incorporate a management system approach into the design, manufacture, test, delivery, and repair of our products and services with the objective of meeting our customers’ expectations for quality and minimizing risks to health, safety, and the environment. We foster a culture of continuous improvement and encourage employees at all levels of the organization to identify opportunities and take action to strengthen our processes and deliver exceptional results. We are committed to providing a workplace which values the health, safety, and wellbeing of our employees, contractors, and visitors to our facilities. We strive to prevent work-related injuries and illnesses, and eliminate or reduce exposure to hazards.

HUMAN RIGHTS
The Company is committed to the elimination of human trafficking, that is, obtaining labor or sex acts through force, fraud, or coercion. We support efforts to encourage disclosure and the responsible sourcing of tin, tantalum, tungsten, and gold (referred to as “conflict minerals” or “3TG”) in our supply chain. We expect our employees and suppliers to commit to the provisions of the Electronic Industry Citizenship Coalition (EICC) Code of Conduct relating to the responsible sourcing of 3TG. We select partners and employees according to a goal of implementing a supply chain that is reliable, socially responsible, and sustainable. We implement a screening process of prospective employees, suppliers, vendors, representatives, and customers to confirm that we are able to conduct business with them.

August 1, 2023