Newell Brands is committed to the highest standards of ethical conduct in all of our business dealings. Our relationship with our suppliers ensures that all businesses have fair and equitable opportunity to participate in any outsourced Newell Brands projects. We are committed to ethical practices that ultimately contribute to our ability to provide innovative, quality products to our consumers and grow our brands.
We invite all suppliers to compete for our business, and in return, suppliers can expect a level playing field. We have no hidden factors in evaluating suppliers and submitted proposals – all relevant decision criteria will be spelled out in advance of soliciting a proposal.
Our employees are prohibited from accepting gifts or gratuities from our suppliers. While our rules do allow for limited exceptions for items of nominal value, the offer or acceptance of gifts is inappropriate and discouraged.
Under no circumstances will our employees solicit any gift or gratuity.
Newell Brands reserves the right to reject any and all proposals and does not bind itself to accept the lowest bid for any materials, products or services submitted. Non-acceptance of any proposal will not imply any criticism of or deficiency in any proposal. Non-acceptance will mean that another approach was deemed by Newell Brands to be more advantageous.
Ethical Standards Manual
Our Ethical Standards Manual and associated processes are in place to allow our partnership with suppliers to be one of fairness and trust. Our program is based upon Newell Brands' Code of Business Conduct and Ethics and Supplier Code of Conduct along with the requirements of our customers' Ethical Standards.
These standards for suppliers cover many areas: child labor, forced labor, environmental, health and safety, discrimination, harassment and abuse, working hours, workers’ compensation, freedom of association and collective bargaining, access for assessments and a set of general requirements. The associated assessment and assessment program covers these areas in greater detail and are addressed in the manual.
In addition to meeting the requirements of Newell Brands' Supplier Code of Conduct and the requirements of our customers, the Ethical Standards Manual and associated processes intend to improve the quality of life of the workers that make the merchandise we supply, comply with legal requirements and global ethical business practices, and insure business processes are in place that comply with the supplier code of conduct.
Supplier Ethical Standards Manual and Procedures
California Transparency in Supply Chains Act of 2010
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 and Ethics 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 Supplier Ethical 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 Global Sourcing personnel 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.
Conflict Minerals Policies
Newell Brands Inc. Conflict Minerals Report
Newell Brands Inc. (and its subsidiaries, collectively “Newell”) is dedicated to conducting business in a lawful and ethical manner.
At Newell Brands, we are well-positioned to drive sustainable growth by building our brands and developing our business systems in ways that responsibly address the use of earth’s resources.
In line with our Corporate Social Responsibility initiatives, this includes a commitment not only to compliance with all applicable laws and regulations, but also to conducting our business worldwide in accordance with our deep respect for human rights.
Along with governments, NGOs, the investment community, and other corporations, Newell Brands is concerned with potential human rights violations, such as forced labor, human trafficking, child labor, and the role armed conflicts may play in such violations across the Democratic Republic of Congo (DRC) and surrounding regions (“the DRC region”).
We understand that these conflicts may be directly or indirectly financed by the mining of and trade in “conflict minerals.” The term “conflict minerals” refers to tin, tungsten, tantalum, and gold (“3TG minerals”), and the ores from which they originate, that are mined in the DRC region. The 3TG minerals are present in the manufacture of a variety of commercial products, including some of our products.
Because of our support for the human rights of all people and our concern that materials in our supply chain may be inadvertently used to limit human rights, we are taking additional steps to understand whether any 3TG minerals that may be contained in our products are used to finance the conflict in the DRC region. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 also requires publicly traded companies to inquire into the origin of 3TG minerals in their supply chains and to report on their due diligence processes and findings in filings with the Securities and Exchange Commission. Newell Brands supports the goals of this regulation.
We will take the following steps to determine the use, source and origin of 3TG minerals in our global product portfolio across our business segments. We will use a reasonable documented process to:
We also commit to institute systems, procedures and strong governance processes to ensure proper implementation of these objectives across the company. Our actions on conflict minerals support and evidence Newell Brands' long-term commitment to respect the human rights of all people and to improve the quality of life in the communities we serve.
- Work closely with our suppliers to determine the potential use of 3TG minerals in our supply chain and, when appropriate, work with them to remediate issues and source more responsibly.
- Expect our 3TG suppliers to conduct the necessary inquiry and, where appropriate, additional due diligence to provide us with confirmation of the source of the materials used in their processes and ultimately present in our products.
- Encourage our suppliers to advocate and actively action our philosophy of sourcing 3TG minerals from socially responsible suppliers, including conflict-free mines in the DRC region.