Introduction
At Novanta, we are committed to ensuring that all forms of modern slavery, including forced, compulsory
labor and human trafficking, are excluded from our business and supply chain. We assess our supply
chain for slavery and forced labor across Novanta business units and adopt these approaches enterprisewide. Our business partners are also expected to act in accordance with the highest standards of integrity
and in compliance with all applicable laws and regulations. The U.K. Modern Slavery Act of 2015 (“UKModern Slavery Act”) requires certain businesses with operations in the UK to disclose their efforts toprevent and address slavery and human trafficking in their supply chains in an effort to eliminate the riskof modern slavery in business operations and supply chains.

About This Statement
This Modern Slavery Statement (“Statement”) is made by Laser Quantum Ltd., an indirect wholly owned
subsidiary of Novanta Inc. located in the United Kingdom (“Laser Quantum” or “we,” “us” and “our”) incompliance with the Modern Slavery Act of 2015. This Statement addresses these laws, policies, andregulations and our commitment to the prohibition of slavery and human trafficking in our supply chain.
The terms “slavery and human trafficking” as used in this Statement include all forms of forced labor
including slavery, child labor, domestic and indentured servitude, human trafficking, sex trafficking, andworkplace abuse.
This Statement covers the policies and activities of Laser Quantum between
January 1, 2022 to December 31, 2022.
This Statement was reviewed and approved by the Board of Directors of Laser Quantum.

2022 U.K. Modern Slavery Act Transparency Statement | Page 2
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0

1Organizational Structure and Supply Chains

Novanta is a leading global supplier of core technology solutions that give medical and advanced
industrial original equipment manufacturers (“OEMs”) a competitive advantage. Novanta combines deep
proprietary technology expertise and competencies in precision medicine and manufacturing, medicalsolutions, robotics, and automation with a proven ability to solve complex technical challenges. This
enables Novanta to engineer core components and subsystems that deliver extreme precision andperformance, tailored to our customers’ demanding applications. The driving force behind its growth is theteam of innovative professionals who share a commitment to innovation and customer success.

About Laser QuantumLaser Quantum is part of Novanta’s Precision Medicine and Manufacturing group which also includes
ARGES, Cambridge Technology, and Synrad. Our Precision Medicine and Manufacturing group delivers
tailored laser and beam delivery solutions to OEMs in a broad range of industrial and medical markets.
We engineer mission-critical core components and subsystems that deliver extreme precision andperformance, enabling our customers to improve productivity, achieve breakthrough performance andenhance people’s lives.iOversight of Human Rights and Other ESG Topics
At Laser Quantum, we view environmental, social, and governance (“ESG”) issues — including humanrights — as central to our growth. Responsibility for strategy and planning related to ESG topics has beenplaced with our Laser Quantum Leadership Team, our senior-most leaders, under the oversight of ourGeneral Manager and the broader Novanta ESG team. The Laser Quantum Leadership Team manages
day-to-day assessment and decision-making around Laser Quantum’s risks and opportunities which
include human rights and supply chain risks, with a focus on our most significant risks. Novanta’s
executive leadership oversees and guides these efforts and, the Novanta Board of Directors, as well as
the ESG Committee of the Board, oversee the corporate governance and sustainability strategy andpolicies and are committed to the operation of Novanta in a responsible manner.
Novanta’s Compliance Manager is responsible for working with Laser Quantum in managing ESG
compliance by Laser Quantum’s key suppliers, which represent the top 80% of its spending. At LaserQuantum, our Quality Manager oversees quality assurance and compliance for the business unit anddirectly engages suppliers on ESG topics, among others.

Laser Quantum’s Supply Chain
Our Code of Business Conduct, our Supplier Code of Conduct and our other policies described in thisStatement convey our values and create the importance of ethical business behaviour within our supplychain and other communities. Laser Quantum purchases a wide range of products and services from its
supply chain, including equipment, supplies and raw materials. We encourage third parties who providegoods and services to us to operate in accordance with these policies and values, to comply with allapplicable laws and regulations, and to implement practices and guidelines that address the issues.

2022 U.K. Modern Slavery Act Transparency Statement | Page 3
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0

2Policies in Relation to Slavery and Human Trafficking

Our commitment to taking steps to identify and eradicate modern slavery risks within our business
operations and supply chain are embodied in our requirement that all employees and suppliers mustcomply with all the relevant laws and regulations in the countries in which they work or operate. Inaddition, this commitment to safeguarding human rights in our operations and supply chain additionally
includes a robust set of policies defining the actions and behaviors we expect from our employees andpartners. These policies include the following Novanta policies that govern Laser Quantum as well:
••

••

•

Code of Business Conduct — Available in eight languages, the Novanta Code of Business Conduct
identifies the ethics, values, and principles that guide our business relationships. We are dedicated todoing business with a strong sense of ethics, honesty, and integrity. The Code of Business Conduct
was written by management and approved by the Board of Directors of Novanta. The Code ofBusiness Conduct provides guidelines on relationships between employees and internal and external
stakeholders, conflicts of interest, anti-corruption, protection of assets, and more. All employees anddirectors are responsible for upholding the Code of Business Conduct.
Supplier Code of Conduct — Novanta’s Supplier Code of Conduct outlines the policies andprocedures with which we expect our suppliers to comply. This Supplier Code provides guidelines onlabor rights, ethics, conflict minerals due diligence, regulatory compliance, and more. Laser
Quantum’s key suppliers—defined as the top 80% of direct material suppliers by spend and criticalmaterial suppliers—are required to sign and adhere to the most recent Supplier Code of Conduct.
Human Rights Policy — Laser Quantum condemns all forms of child, forced, unpaid or compulsory
labor and human trafficking. We expect the same from our business partners and suppliers.
Novanta’s Human Rights Policy details the various laws and regulations related to human rights that
we adhere to and the ethical standards we expect all our leaders, employees, and partners to adhere
to.
Equal Employment Opportunity Policy — Laser Quantum is firmly committed to compliance withall federal (including national/UK), state and local laws that prohibit employment discrimination on thebasis of age, race, color, gender, gender identity, gender expression, sex, sex stereotyping,pregnancy, national origin, ancestry, religion, physical or mental disability, medical condition, maritalstatus, citizenship status, sexual orientation, protected military or veteran status, genetic informationand other protected classifications.
Anti-Harassment Policy — Laser Quantum prohibits and does not tolerate any unlawful harassment
against employees or any other covered persons because of race, color, religion, creed, national andor ethnic origin, ancestry, sex, pregnancy and maternity, parenthood, marital or familial status,
gender, gender identity, age, sexual orientation, disability, chronic disease, citizenship, politicalopinion, genetic information, domestic violence victim status, or service in the uniformed services, orany other characteristic protected under applicable federal (including national/UK), state, or local law.

2022 U.K. Modern Slavery Act Transparency Statement | Page 4
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0

3Due Diligence

In 2022, we launched with Novanta an internal assessment of our own operations to ensure we areadhering to human rights standards set forth in our Code of Business Conduct and Human Rights Policy.
We assessed all Laser Quantum sites for compliance with these policies including:
••
•••••

Human Rights Reporting
Employee Health & Safety
Working Conditions
Social Dialogue
Career Management & Training
Child Labor, Forced Labor & Human Trafficking
Diversity, Discrimination & Harassment

No violations were identified during our 2022 assessment. We plan to conduct annual assessments ofhuman and labor rights in our own operations.

Our Supply Chain
Novanta and Laser Quantum screen all new key suppliers for financial, legal, and business ethical risks.
All new suppliers are required to agree to adhere to our Supplier Code of Conduct. They are also audited
for the purpose of assurance and compliance and required to complete a self-assessment annually orbiennially depending on their level of risk. In 2023, audits and self-assessments will include ESG criteria,
including labor rights and working conditions.
Laser Quantum also completes the Slavery & Trafficking Risk Survey Template (STRT), disclosing ourlocations of operations, human rights policies, supplier screening, and potential risks, on an annual basis.

4Risk Assessment and Management

Novanta’s Internal Audit function performs an annual update to Novanta’s enterprise risk assessment byconducting interviews of various senior leaders within Novanta (including Laser Quantum). All risks areranked based on both the likelihood of occurrence and the severity of the potential impact. Human rightsrelated risks are not currently included in the enterprise risk assessment processes due to the low level ofperceived human rights risk in our industry, but our risk assessments are updated for changes in thebusiness environment annually and human rights topics may be added to our risk assessment processes
in the future.

2022 U.K. Modern Slavery Act Transparency Statement | Page 5
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0

5Key Performance Indicators

We are committed to ensuring high standards of human rights within our supply chain. We assess
progress towards reaching our human rights objectives through monitoring the three key performanceindicators as below.
Key Performance Indicator
Laser Quantum 2022 Progress
100% of key suppliers have signed off on the latest Supplier Code of Conduct.
Laser Quantum has achieved this KPI as of the date of this Statement.
On-site audits have been completed for every key supplier at least once every three years.
A majority of Laser Quantum’s key suppliers have been audited in the last three years. We are
expanding the scope of such audits to include human rights audit procedures.
95% of Laser Quantum employees have completed ethics training and signed latest Code of BusinessConduct.
Laser Quantum has achieved this KPI as of the date of this Statement.

6Training on Modern Slavery and Trafficking

New and existing employees are required to regularly pass training courses on ethics, anti-bribery andanti-corruption, harassment, and data privacy policies. Additionally, all employees are required toannually certify that they understand and uphold the Novanta Code of Business Conduct, anti-bribery andanti-corruption, and harassment policies.
In 2023, Novanta intends to launch a new training module related to ESG topics for employees inpurchasing roles, including those of Laser Quantum, on its internal learning and development platform,
Novanta University. This training will include information about slavery and human rights.

2022 U.K. Modern Slavery Act Transparency Statement | Page 6
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0

7Conclusion

At Laser Quantum, we are committed to reflecting our values in the way we do business both internally in
our own operations and externally with the partners we choose to work with. We strive to uphold both thespirit and letter of all human rights laws in all countries in which we do business.
These laws, along with our own internal policies, protect our employees, contractors, workers anywhere in
our supply chain and any other persons impacted by or doing business with us. We aim not only for fullcompliance but also to avoid adverse impacts on human rights by focusing on the perspective of each
employee.
This Statement was approved by the General Manager and the Board of Directors of Laser Quantum Ltd.
as of June 28, 2023.
/s/ Gunnar Stolze
Gunnar Stolze
President and General Manager
Laser Quantum Limitedi https://www.linkedin.com/company/laser-quantum-a-novanta-company/

2022 U.K. Modern Slavery Act Transparency Statement | Page 7
Be mindful of our environment, don’t print if you don’t need to.

June 2023 | V1.0