UK Modern Slavery Act Statement

August 12, 2020

Introduction

 
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Newell Brands, Inc. and its subsidiaries ("Newell") have taken, and are continuing to take, to ensure that modern slavery, forced labor or human trafficking are not taking place within Newell’s business or supply chain.

Newell is a leading global consumer goods company. Newell rigorously applies high standards of corporate governance and ethics to its business and emphasizes transparency and accountability. Modern slavery encompasses slavery, servitude, human trafficking and forced labor. Newell maintains a zero-tolerance stance on these issues. Newell is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery, forced labor and human trafficking.

Organizational structure and business
Newell has its headquarters in the US and is recognized as a leading global consumer goods company with a strong portfolio of well-known brands, including Paper Mate@, Sharpie@ Dymo@, EXPO@, Parker@, Elmer's@, Coleman@, Marmot, Oster@, Sunbeam@, FoodSaver@, Mr. Coffee@, Rubbermaid Commercial Products@, Graco@, Baby Jogger@, NUK@, Calphalon@, Rubbermaid@, Contigo@, First Alert@, and Yankee Candle@.

Newell sells its products in nearly 200 countries around the world, with operations on the ground in over 40 of these countries,including in the North America, Latin America, Europe, Middle East, Africa and Asia-Pacific regions.

Newell is organized into the following 8 business units: Home Fragrance; Baby; Writing; Food; Appliances & Cookware; Outdoor & Recreation; Commercial; Connected Home & Security.
This statement has been approved by the Newell Board of Directors on the date set out at the top of this statement and also applies to all subsidiaries of Newell (as at the date of this statement) which meet the criteria set forth in the Modern Slavery Act 2015.

Relevant policies and tools 

Newell utilizes the following policies and procedural documents that describe the company’s approach around human rights, responsible sourcing and ethical standards including the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in Newell’s operations:

  • Code of Conduct 
  • Vendor Code of Conduct 
  • Vendor Code of Conduct Audit (means a social compliance audit carried out by Newell against its supplier to ensure the supplier is complying with Newell’s Vendor Code of Conduct) 
  • Supplier Business Ethics guidelines 
  • Global Procurement Policy 
  • Responsible Sourcing Manual 

Newell's Code of Conduct is key to the company’s continued growth and reflects a commitment by every employee to an ethical workplace. Newell's Code makes clear to employees the actions and behavior expected of them when representing Newell. Newell strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain. Specifically, Section 2.3 of Newell's Code of Conduct states:

“We prohibit inhumane labor practices. Our Company complies with laws and regulations directed at protecting the health and safety of the global workforce. We comply with legislation focused on eliminating slavery and human trafficking from global supply chains, including the UK Modern Slavery Act. Our Company rejects, and will not knowingly use business partners that engage in, inhumane labor practices, including:

  • The exploitation of children and the use of child labor 
  • Physical punishment 
  • Forced or compulsory labor 
  • Human trafficking. 

As part of our commitment to human dignity, we select vendors, suppliers and business partners who certify that they are committed to the health and safety of their workers, do not use forced labor or materials or goods produced by forced labor and implement supplier programs that ensure no materials used in our products come from sources that commit human rights violations."
Newell uses only specified, reputable employment agencies to source labor and verifies the practices of any new agency before accepting workers from that agency.

Newell is committed to ensuring that its suppliers adhere to the highest standards of ethics. Supplier requirements are outlined within both Newell’s Code of Conduct and Vendor Code of Conduct. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labor. Newell works with suppliers to ensure that they meet the standards of Newell’s Vendor Code of Conduct and improve their worker's working conditions. Each supplier is required to acknowledge and agree to Newell's Vendor Code of Conduct and serious violations of Newell's Vendor Code of Conduct may lead to the termination of the business relationship. Specifically, the Vendor Code of Conduct states:

“Vendors shall not use any prison, indentured, bonded or forced labor. No employees shall be forced to remain employed other than on a voluntary basis. Foreign employees must be employed in full compliance with the labor and employment laws of the host country. The contract terms under which such employees are employed must be in writing, in a language that the employees can read and understand, and accepted by the employees prior to their departure from their home countries. Supplier must not withhold the passports and visas of foreign employees. Vendor shall maintain and commit to maintaining a work environment that is free from human trafficking. Employment practices must not include the recruitment, transportation, transfer, harboring or receipt of persons, or through the use of force or through other forms of coercion, abduction, fraud, deception, abuse of power or by giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.”

Newell encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Newell. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Newell's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can confidentially contact the company’s Ethics Hotline

Risk assessment and due diligence 

The greatest potential risk of slavery and human trafficking can exist in supply chains. Newell believes that the risk of slavery and human trafficking is mitigated by clearly established standards, oversight and quality controls within Newell’s sourcing process, social compliance verification process and business operations.

Newell conducts due diligence when considering engaging new suppliers and regularly reviews its existing suppliers. Newell's due diligence and reviews include: capabilities assessment, financial verification, Vendor Code of Conduct Audits, and Newell’s Vendor Code of Conduct review prior to commencing business with a supplier. For existing suppliers, annual Vendor Code of Conduct confirmation and social compliance trainings including developing corrective action plans are completed. Newell has an established escalation process for suppliers that fail to improve their performance in accordance with an action plan or seriously violate Newell’s Vendor Code of Conduct.

Newell’s Progress 

Newell’s goal is to audit 100 percent of our finished goods suppliers on a three-year rolling basis, and to conduct more than 600 audits each year. In 2019 Newell conducted and reviewed 692 Vendor Code of Conduct Audits to assess suppliers on human rights, which puts us in position to attain this goal. Audit topics include: forced labor, child labor, working hours, freedom of association and environmental, health & safety. Newell’s program is built upon a continuous improvement platform that utilizes the audit as a starting point for driving long-term sustainable improvements with suppliers. Newell has an escalation process in place for high risk violations to ensure full issue resolution. Newell’s Vendor Code of Conduct Audit includes standards on forced labor to ensure active monitoring and address any potential risks within the supply chain. Below are some examples of the criteria outlined in the audit:

Risks Audit Criteria Supplier Development 
Policy/Procedures 
  • Factory policies, procedures, practices for obtaining, implementing, and retaining information on local and national labor and employment laws and regulations 
  • Factory policies and procedures related to wages and benefits, working hours, hiring procedures, forced labor, discrimination and harassment, health and safety, freedom of association, business ethics, and subcontracting 
  • Maintenance of factory procedure manuals and employee handbooks 
  • Proper documentation and maintenance of worker personnel files and records, including labor contracts to verify if the factory is properly signing the contract with all 

Newell holds year-round trainings focused on supplier development and continuous improvement in the supply chain. Examples of topics include forced labor and worker recruitment practices. 2019 trainings included: 

  • Webinar trainings (Quarterly) 
  • Forced labor training (July) 
  • Annual supplier training focused on meeting Newell’s Vendor Code of Conduct requirements (October, 2 sessions) 
  • Employees Code of Conduct training (Periodic) 
Factory Management Systems 
  • Agreements for services with third parties include clauses prohibiting harassment and abuse 
  • • Mechanisms to confirm employment agency(s) have valid business license/ permit in accordance with local laws 
  • • Training for employees with recruitment responsibilities on risks and identification of modern slavery and human trafficking during recruitment process 
  • • Safe factory conditions across all health & safety related areas, from but not limited to building, fire safety, workplace condition & ventilation, chemicals handling, machines and special equipment, occupational diseases, personal protective equipment, first aid and emergency facilities, access to clean drinking water, toilets, etc. 
  • Each supplier receives a Corrective Action Plan highlighting audit findings and recommended corrective action(s) 
  • • The supplier must complete recommended corrective action(s) within a specific timeframe according to severity 
  • • Suppliers are to apply root cause analysis to establish long-term solutions to the findings. 
Migrant Labor 
  • Terms of contract are in writing, and in a language the employee can read, understand, and accepted 
  • Wages are paid directly to the employee and no practice of withholding wages or forced saving 
  • Travel and personal identification documents are in the possession of the workers 
  • Proper documentation supporting that all legally mandated benefits and allowances are provided 
  • Review of employee timecards, piece rate records, pay stubs, other applicable personnel/employer payroll records, production related or other records for random pay periods to verify wages 
  • Risk assessments across finished goods suppliers 
  • Joint training activities with finished goods suppliers to mitigate impact 

Performance indicators 

Newell has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act of 2015 and conducts reviews on an annual basis. As a result, Newell:

  • Conducted trainings on forced labor to educate suppliers; 
  • Continued to perform audits against its Vendor Code of Conduct; 
  • Utilized its supplier verification process to evaluate potential suppliers before they enter the supply chain; 
  • Escalated potential high-risk issues to the relevant parties within Newell with actionable steps, up to, and including, the supplier’s removal from Newell’s supply chain; and 
  • Recalibrated its program and updated the Newell’s Vendor Code of Conduct Audit to ensure that criteria align with emerging trends and current regulatory landscape. 

Newell’s Corporate Social Responsibility team works closely with the business units and its suppliers to ensure they establish a proactive culture around human rights. Newell’s Responsible Sourcing Manual is a resource provided to suppliers to ensure they fully understand the social compliance requirements and to assist them with proactively managing human rights within their factories.

For more information on Newell’s Corporate Social Responsibility program please review the Newell Vendor Code of Conduct and Responsible Sourcing Manual at https://www.newellbrands.com/business-ethics

Board Approval 

This statement has been approved by Newell's Board of Directors, who will review the statement and applicable updates annually.

Sincerely,

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Patrick D. Campbell
Board Chair