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.