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CA Transparency in Supply Chains Act and UK Modern Slavery Act Required Disclosure

As part of our standard terms and conditions and principles of supplier conduct, we require our suppliers to comply with all applicable laws and not to engage in or support the use of child labor or forced or involuntary labor. We have also recently implemented our Global Anti-Human Trafficking Policy which applies to our own operations as well as those of our suppliers and subcontractors. We strive to continuously improve our efforts in this area, and from time to time will communicate our progress. Under the California Transparency in Supply Chains Act of 2010 and UK Modern Slavery Act 2015, we make the following disclosures:

Verification: We expect our suppliers and subcontractors to comply with applicable laws and our policy prohibiting the use of child labor or forced or involuntary labor. With respect to certain government contracts, certain covered contractors and suppliers are expected to confirm through agreement to Watts’ terms and conditions that neither the covered subcontractor nor its agents are engaged in any trafficking-related activities and the covered subcontractor has taken action to remedy and report any such trafficking-related activities. Beyond that, we do not currently engage in verification of product supply chains to evaluate and address the risks of human trafficking and slavery in the supply chains.

Audits: We do not currently conduct audits of suppliers to evaluate their compliance with company standards for human trafficking and slavery in supply chains.

Certification: With respect to certain government contracts, certain covered contractors and suppliers are expected to confirm through agreement to Watts’s terms and conditions that neither the covered subcontractor nor its agents is engaged in any trafficking-related activities, and the covered subcontractor has taken action to remedy and report any such trafficking-related activities. Beyond that, we do not currently require our suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which these suppliers are doing business.

Accountability: Under our Global Anti-Human Trafficking Policy we maintain internal accountability standards and procedures to address employees, contractors or suppliers who fail to meet company standards regarding slavery and human trafficking.

Training: We publish our relevant policies prominently on our website, and from time to time make our employees aware of such policies. However, we do not currently conduct training on human trafficking and slavery to company employees and management who have direct responsibility for supply chain management, including with respect to mitigating risks within the product supply chain.

 

ADOPTED: December 13, 2018