Spectrum Brands, Inc. January 1, 2012
California Transparency in Supply Chains Act of 2010 -- Corporate Disclosure
Spectrum Brands, Inc. (and its affiliates and subsidiaries, collectively "Spectrum") is committed
to the highest standards of business conduct in its relationship with its customers, suppliers,
shareholders and others and strives to conduct its business in accordance with the highest
standards of business ethics. This includes Spectrum’s commitment to conducting its business
in a manner that ensures the absence of slavery and human trafficking in its supply chain.
To meet this goal, Spectrum expects and requires each of its suppliers to conduct business
in a lawful and ethical manner including business practices that prevent or eliminate slavery
and human trafficking in its supply chain. Spectrum communicates this expectation by requiring
all Suppliers who provide materials and products to comply with
Spectrum’s Supplier Code of Conduct (the “Code”). The Code, among other issues, specifically
forbids the use of slave, forced or involuntary labor of any kind, including unlawful child
labor and prohibits Suppliers from maintaining supply chains that engage in human trafficking.
The Code includes a certification signed by the Supplier acknowledging its responsibility for
adhering to the standards of the Code. Suppliers must also ensure that the Code is observed by
Suppliers’ subcontractors, business associates or employees. Spectrum identifies and utilizes
Suppliers who share its commitment to ensure the absence of slavery and human trafficking in its
supply chain and reserves the right for itself or through third party auditors, to conduct, or
have conducted on its behalf, unannounced audits of production facilities and business practices
to monitor Suppliers’ commitments. Where Spectrum deems appropriate it may provide a
non-compliant Supplier the opportunity to remedy the non-compliance through implementation of
a corrective plan. If the Supplier fails to meet Spectrum’s standards, Spectrum will seek to
terminate the Supplier from its supply chain. Spectrum reserves the right to cease doing business
with any Supplier who is not in compliance with the Code.
In addition, Spectrum’s retail and commercial customers (collectively the “Customers”) concerned
about preventing and eradicating slavery and human trafficking in their supply chains, require
verification through Customers’ audits of Spectrum’s and Spectrum’s manufacturers’ facilities
that Spectrum’s products are manufactured through supply chains that adhere to anti-slavery and
anti-human trafficking policies. Thus Spectrum’s supply chains have been subject to intense
scrutiny under both Spectrum’s and its Customers’ anti-slavery and anti-human trafficking
polices including announced and unannounced audits) prior to and after the passage of the
California Transparency in Supply Chains Act of 2010.
Spectrum is committed to implementing and maintaining ongoing training of its employees
and consultants on slavery and human trafficking to recognize and mitigate these risks in
its supply chains.
Additionally, Spectrum supports the ETI Base Code stated in the Ethical Trading
Initiative implementing human rights, ethical labor practices, and environmental protection
standards. The Initiative is available at www.ethicaltrade.org.
Spectrum’s Supplier Code of Conduct (described above) requires that employment is freely
chosen and not forced in addition to other similar commitments to ensure the absence of slavery
and human trafficking in Spectrum’s Suppliers supply chains.
For more information on Spectrum's commitment to ensure the absence of slavery and human
trafficking in its supply chains, click on the Code link above. Spectrum reserves the right
to amend this Disclosure at any time without notice.