California Transparency In Supply Chains Act of 2010 and united kingdom modern slavery act of 2015

Ecolab’s Response to the California Transparency in Supply Chains Act of 2010, United Kingdom Modern Slavery Act of 2015

Ecolab’s Ethical Sourcing Standards represents a global supply chain initiative requiring our direct suppliers to protect the health, safety and human rights of their employees. Suppliers must meet standards regarding forced labor, child labor, health and safety, fair pay and harassment in the workplace. We require that our suppliers identify and act swiftly to eliminate any unacceptable conditions or practices in their facilities. We will not do business with suppliers who do not support the fundamental principles of human dignity and rights of workers to fair and equitable treatment. We base our supplier requirements on international standards including the United Nations Universal Declaration of Human Rights, the United Nations Convention on the Rights of the Child, and the Conventions of the International Labour Organization, including its Fundamental Principles and Rights at Work.

The California Transparency in Supply Chains Act of 2010 (SB 657), effective January 1, 2012, requires certain companies to disclose information regarding their efforts to eradicate slavery and human trafficking from their supply chains. The United Kingdom’s Modern Slavery Act, adopted in 2015, requires similar disclosures of certain companies doing business in the United Kingdom.

In accordance with these Acts, Ecolab’s disclosures are as follows:

1. Verification. In order to evaluate and address risks of human trafficking and slavery in its supply chains, Ecolab has developed a detailed supplier ethical assessment that suppliers in parts of Ecolab’s business where there is an elevated risk of slavery and human trafficking must complete in order to verify compliance with Ecolab’s ethical sourcing requirements. Ecolab has required such suppliers in the chemical, packaging, equipment and contract manufacturing categories to complete the assessment, and we continue to expand the number and scope of suppliers required to complete the assessment. Suppliers are questioned not only on their policies, but on management practices and specific performance related to protection of employees’ human rights and prevention and elimination of trafficking and slavery.
    
2. Auditing. Ecolab does not currently conduct on-site audits of suppliers related to trafficking and slavery in supply chains, but is evaluating whether to expand its existing auditing program to incorporate trafficking and slavery standards.
   
   
3. Certification. Ecolab requires all suppliers to comply with applicable government regulations, as well as with Ecolab policies and procedures, including Ecolab’s Global Anti-Human Trafficking Policy. We communicate our policies to relevant suppliers on an annual basis, but do not currently require certification.
   
   
4. Accountability. Ecolab’s employees are held internally accountable for ensuring that Ecolab meets its standards regarding slavery and trafficking through Ecolab’s Code of Conduct and Global Anti-Human Trafficking Policy. The Code of Conduct requires employees and contractors to engage in ethical source selection. It also makes clear that compliance with applicable government regulations and Company policies and procedures is required of all Ecolab suppliers, agents and consultants. The Global Anti-Human Trafficking Policy provides additional detail regarding the specific requirements and prohibitions on Ecolab directors, officers and employees, as well as agents, subcontractors, suppliers, distributors and vendors with respect to prevention of trafficking-related activities.
   
   
5. Training. Ecolab provides training to its supply chain and purchasing employees, as well as to its suppliers, regarding Ecolab’s ethical sourcing policies and procedures, which include a modern slavery element.