Policy Regarding Conflict Minerals

Effective December 20, 2013

Spectrum Brands, Inc., including its subsidiaries (collectively “Spectrum”) is committed to sourcing components and materials from companies that share its values about human rights, ethics and environmental responsibility.

Spectrum supports the goals and objectives of Section 1502 of the Dodd-Frank Act, (the “Act”) which aims to prevent the use of conflict minerals that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or an adjoining country as defined in the Act. Conflict minerals include: columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives and could expand to include any other mineral or their derivative determined by the U.S. Secretary of State to be financing the DRC conflict. The Act requires companies to perform due diligence with respect to the sourcing of conflict minerals and to file annual reports relating to use of conflict minerals. Spectrum is actively working toward complying with the conflict minerals diligence and reporting obligations required under the Act, and ensuring its activities are not contributing to the armed conflict in the DRC and adjoining countries. Through these actions, Spectrum expects to support peaceful negotiations in the DRC and neighboring countries and a responsible, sustainable minerals trade and stable economies.

Spectrum is addressing conflict minerals on two fronts: (a) its suppliers and (b) itself and its subsidiaries.

SPECTRUM’S SUPPLIERS

The suppliers are required to comply with Spectrum’s Supplier Code of Conduct, which includes requirements relating to conflict minerals and responsible sourcing. Suppliers are responsible for passing these same requirements onto their suppliers.

Spectrum's Supplier Code of Conduct requires suppliers to implement a policy and process to reasonably assure that the mining of the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that perpetrate human rights abuses in the Democratic Republic of the Congo or an adjoining country. Suppliers must exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to Spectrum. If suppliers fail to adhere to the conflict mineral terms in the Supplier Code of Conduct, Spectrum may take action including terminating any non-compliant supplier.

Additionally, Spectrum encourages its suppliers to reasonably source conflict minerals and derivative metals from the DRC and neighboring countries from mines and smelters that do not fund armed groups engaged in conflict and human rights abuses (conflict free mines and smelters) to prevent an embargo and associated worsening of economic conditions and human suffering.

Spectrum appreciates the commitment of its suppliers to the goal of using conflict-free minerals in its products.

SPECTRUM’S ACTIONS

Spectrum is taking action to develop robust due diligence processes and to educate and seek information from its suppliers to ensure compliance with federal laws and regulations. The first SEC report must be filed by May 31, 2014 for the 2013 calendar year.

Spectrum is basing its due diligence processes, in part, on the guidance provided by the Organization for Economic Co-operation and Development (OECD). The framework of the OECD provides practical guidance to companies on a set of actions that can be taken throughout its supply chain to ensure responsible due diligence. Spectrum established a steering committee (across all of its divisions) comprised of executive leadership to work through the OECD framework and has developed a plan to address each of its focus areas. Spectrum is incorporating training of its employees and contractors and will incorporate evaluation tools to measure improvement in communication of and adherence to its plan.

Spectrum will provide updates as this process moves forward regarding its plans and actions to comply with SEC conflict mineral requirements and associated timelines.

Spectrum reserves the right to revise this policy at any time and will include the new effective date of such revised policy.