Corporate Responsibility Statement

COMMUNITY
At Comtech, we have approximately 2,000 employees and contractors and they live and or do business in over 40 countries around the world to serve our customers in their communities. Comtech’s mission is to create value for investors by building the equipment that connects communities around the world and providing critical communication services such as 911 emergency call service. We make Connections That Matter™.

While protecting the health and safety of our team and our families, we continued to help others during the COVID-19 pandemic by not losing sight of our pursuit to strengthen mission critical technologies that make communities safer and help businesses stay productive and secure.

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.comtechtel.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 two women (one of whom is the Board’s first African-American) within the past two years, each of whom chairs a Board Committee. Within the ranks of our executive management, two women have assumed leadership roles recently, as Managing Counsel and Treasurer. In addition, a newly created management position of Chief Trade Compliance Officer was filled by an African-American in 2020. 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.

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.