Newell Brands Inc. (and its subsidiaries, collectively “Newell”) is dedicated to conducting business in a lawful and ethical manner. We are also committed to preventing any occurrence of slavery and human trafficking from our supply chain. Our Code of Conduct specifically prohibits labor practices that are inhumane or which endanger the health and safety of our workforce and emphasizes our commitment not to do business with individuals or companies that engage in forced labor, unlawful child labor and/or human trafficking. Accordingly, it is our expectation that the manufacturers and suppliers with whom we do business will share our commitment to fair and safe labor practices and conduct themselves in a lawful and ethical manner. Consistent with this commitment, we have developed our Responsible Sourcing Standards, which prohibits the use of unlawful child labor and forced or involuntary labor of any kind. Additionally, we have also revised our standard Master Purchase Agreement to require our suppliers to represent and warrant that all labor and/or materials used in connection with the provision of any products provided to us were “employed and/or produced in compliance with applicable laws forbidding slavery and human trafficking.”
In order to ensure compliance with these obligations upon behalf of our suppliers, Newell has developed a detailed process to evaluate a supplier’s compliance with our Supplier Ethical Standards. Through this process, we conduct periodic, announced and unannounced assessments of our suppliers designed to verify their compliance with our Supplier Ethical Standards. These assessments are conducted by Newell Brands Corporate Social Responsibility team or a third party, as appropriate. Employees tasked with supplier compliance as well as other employees with direct responsibility for supply chain management are provided training on human trafficking and slavery, including ways to mitigate the risks of these practices within our supply chain. Since our employees have been trained to identify non-compliance, they are expected to report to our Vice-President of Global Sourcing, the Ethics and Compliance Team or the Legal Department any potential unlawful or unethical conduct within the supply chain.