Code of Conduct

Table Of Contents
Message from Chris Peterson �����������������������������3

4.0 We commit to our marketplace
4.1 Engage in fair dealing ���������������������������������������������������28

1.0 We commit to doing the right thing

4.2 Ensure product safety ��������������������������������������������������29

1.1 Our People & Purpose ������������������������������������������������� 5

4.3 Avoid insider trading �����������������������������������������������������30

1.2 Our Code of Conduct �������������������������������������������������� 6

4.4 Comply with competition laws ������������������������������������31

1.3 Our Speak-Up Culture ������������������������������������������������� 8

4.5 No bribery ���������������������������������������������������������������������32

2.0 We commit to each other

4.6 Prevent money laundering �������������������������������������������34

2.1 Promote respect in the workplace ���������������������������� 12

4.7 Comply with trade compliance laws ���������������������������35

2.2 Maintain a healthy and safe workplace �������������������14
2.3 Ensure fair employement practices ������������������������� 16

5.0 We commit to our community
5.1 Protect our natural environment ����������������������������������37

3.0 We commit to our Company

5.2 Source responsibly �������������������������������������������������������38

3.1 Maintain accurate books and records ����������������������18

5.3 Contributions ����������������������������������������������������������������39

3.2 Avoid or disclose conflicts of interest ����������������������20
3.3 Appropriate gifts and entertainment ������������������������21

Resources ��������������������������������������������������������������������������40

3.4 Protect and use Company assets responsibly ������� 22
3.5 Communicate about our Company responsibly ������24
3.6 Safeguard confidential information ��������������������������25
3.7 Protect the privacy of personal data ������������������������26

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Message from Chris Peterson
Colleagues,
At Newell Brands, at every level of the company, we’recommitted to acting with integrity, treating others with
dignity and respect, adhering to the highest ethical standards
and operating in full compliance with the law.
As we work together as One Newell to advance our businesspriorities, delight consumers and win in the marketplace, we must
demonstrate this commitment in all we do and recognize that how
we achieve our results is as important as the results themselves.
Our Code of Conduct guides us in these efforts. It establishes
clear guidelines to help us make ethical decisions consistently
as we conduct business globally – for example, dealing withindustry groups and vendors and avoiding conflicts of interest.
I ask each of you to review our Code and join me in upholding
its principles in our work and interactions every day.
Thank you for your continued efforts and commitment
to ensuring we operate ethically and responsibly.
Sincerely,
Chris Peterson
President & CEO

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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1.1 Our People & Purpose
1.2 Our Code of Conduct
1.3 Our Speak-Up Culture

1.0
We commit to doing
the right thing
Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Our People & Purpose
With shared Purpose and Values and a desire to be a force forgood in the world, our people strive to meet and exceed customer
and consumer needs while making the planet a better place andfostering an inclusive environment where all are welcomed andvalued. Our global workforce embraces a diverse collection ofskills, experiences, abilities and backgrounds to build leading
brands, drive innovation and create stakeholder value.
Our commitment to operating ethically extends beyond our walls
to our consumers’ lives and homes where we deliver superior
product innovation, design and performance. It is only by treating
our consumers, customers, communities and each other withrespect that our beloved, planet-friendly brands may enhanceand brighten consumer’s lives at home and outside by creating
moments of joy, building confidence and providing peace of mind.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Our Code of Conduct
The key to our continued success is our commitment tooperating ethically. Our Code reflects this commitment
by embodying our Values of integrity, teamwork, passion
for winning, ownership and leadership. Our Code guides
us on how to make ethical decisions, but it cannot
cover every situation that may arise. It is importantfor you to use your good judgment to make choicesthat are consistent with our Company’s Values.
We must apply our Code consistently in all of ourbusiness dealings. When a local practice suggests a
standard that is less stringent than our high standards,
you should follow our Code. If you have questions
about specific laws or regulations, or if you believe
there is a conflicting legal obligation under the lawsof different countries, contact the Legal team.
Make sure you understand our Code. If you are unclear
about your responsibilities, or what the right thing to
do is, speak up and ask. You will be required to certify
annually that you have read and complied with our Code.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Our Code applies to all of us· Employees of Newell Brands

regardless of location, seniority,business unit or function· Members of our Board of Directors· Executive Officers· Third parties working on our

Company’s behalf, including
agents, representatives,
independent contractors andconsultants

We all must follow the provisions in ourCode. Keep in mind that violations of ourCode may result in disciplinary action, in
accordance with applicable law, up to andincluding termination; and, in some cases,
legal action.
If you believe that you require a waiver ofa specific provision, request approval fromthe Chief Ethics and Compliance Officer.
Executive officers and directors must
submit waiver requests to the Nominating/Governance Committee of the Board of
Directors. If approved, Newell Brands willpromptly disclose such waivers as requiredby law.

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Managers set the tone for an
ethical workplace
Managers are responsible for ensuringthat their teams act with integrity. If you
are a manager, we look to you to:· Set a good example.
· Understand our Code, as

well as the policies and lawsthat apply to your team.

· Promote a speak-up culture where

employees feel comfortable asking
questions and raising concerns.

· Report ethics and complianceconcerns through theappropriate channel.

· Never respond in a retaliatory

Q&A
Q My manger asked me todo something that I’m
uncomfortable with, but I’m
not sure if it is a violation of
our Code. What should I do?
A Report the situation to
Ethics and Compliance or
Human Resources. If therequest makes you feel
uncomfortable, you should
let someone know.

manner and ensure your teamunderstands the importanceof our non-retaliation policy.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Our Speak-Up Culture
When you seek advice, raise a concern, report suspected
misconduct or cooperate with an investigation you
are complying with our Code and living our Values.
Our Company believes in creating a culture where
employees feel comfortable speaking-up and knowingthat if you do speak up, you will be heard. You may
reach out to your manager, Human Resources, or anyof the resources listed on the Resources page.
We all have a responsibility to report actual or suspectedviolations of our Code of Conduct. Ignoring problems
makes them worse and can harm others or our Company.
If you receive a report, do not investigate it yourself,
instead forward it to the Ethics and Compliance team.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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What is the Ethics Hotline?
The Ethics Hotline is a confidential way to ask questions orshare concerns about potentially unethical conduct. The
hotline is operated by an independent, third-party company
and is available 24 hours a day, 7 days a week.
When you contact the Ethics Hotline you may make a reportin your own language. Your report will be documented andsent to the Ethics and Compliance team to address promptly,
discreetly and, to the extent possible, confidentially.

What happens after I make a report to the
Ethics Hotline?
Ethics and Compliance will inform you that we have received
your report. We will objectively investigate your report,
requesting support from other Company functions, as needed.
To ensure that we are able to conduct a thorough investigation,
you may be contacted for details related to your report.
You have an obligation to cooperate with all internal investigations.
This means that you must respond to inquiries truthfully andtransparently and provide information that is requested.
Ethics and Compliance will inform you when the investigation iscomplete. The results of the investigation may not be disclosed
to you; but rest assured that the Company takes findings of
misconduct seriously and will ensure we address any issues.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q&A

Q I am not satisfied with the resolution of a report I
made to the Ethics Hotline. What should I do?
A Contacting the Ethics Hotline initiates a process
designed to ensure a thorough review of your concernthat concludes with an appropriate resolution,
including addressing conduct that does not meet
our standards. If you continue to have concerns
after an investigation is completed, contact Ethics
and Compliance for additional consideration.
Q I reported conduct that concerned me to my manager,
but she told me not to worry about it. What should I do?
A If you are not satisfied by your manager’s
response to your report, reach out to Ethics
and Compliance. You should feel that yourconcerns are being heard and addressed.

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Our Non-Retaliation Policy
You will not be retaliated against in any way for raising a
concern in good faith. Raising a concern in “good faith”
means that you are sincere in providing honest and accurate
information, even if it later turns out that you are mistaken.
Forms of retaliation include losing your job, being demoted,
suspended, threatened, harassed, victimized or being
discriminated against. Retaliation is illegal and we take claimsof retaliation seriously — anyone found to have committed
a retaliatory act is subject to disciplinary action, up to andincluding termination. If you or someone you know is the victim
of retaliation, report it immediately. If you are ever concerned
about your personal safety, contact Global Security.

Q&A
Q I suspect that my manager is engaging in inappropriate
conduct. Should I be concerned about promotion
opportunities if I make a report involving him?
A No. You will not be subject to retaliation, including
an adverse impact on potential career opportunities,
for making a report in good faith. If you areconcerned that something is wrong, you have an
obligation to speak up and make a report.
Q Will I get in trouble if I am involved in the
misconduct that I am reporting?
A There may be consequences for your actions;however, by speaking up about the conductand cooperating with the investigation, you will
be protected from any retaliatory actions.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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2.1 Promote respect inthe workplace
2.2 Maintain a healthy andsafe workplace
2.3 Ensure fair employment
practices2.0
We commit toeach other
Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Promote respect inthe workplace
We believe that employees are the most fulfilled, engaged
and successful when they are encouraged and empowered
to bring their whole selves to work, and we fundamentally
believe diversity of thought and experience is essential toinnovation and growth. In this spirit, we aim to foster anenvironment where all employees feel welcome and valued.

OUR COMPANY DEFINES DIVERSITY,
INCLUSION AND BELONGING (DI&B) AS:
Diversity: The blending of many backgrounds,
experiences and perspectives within our teams.
Inclusion: Fostering a collaborative workplacethat equally values open participation fromindividuals with different ideas and viewpoints.
Belonging: The ability for employees to feelempowered to bring their whole selves to work.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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No harassment
We must ensure a respectful working environment, freeof inappropriate behavior and harassment. You must
speak up about intimidating, hostile or offensive workplace
behavior, including:· Making offensive comments, jokes, or slurs.
· Sharing or sending offensive pictures,images, or communications.

· Making sexual remarks, sexual advances, andinappropriate touching or gestures.

· Name calling or directing profanity or threats at
another individual.

No discrimination
We recruit, hire, evaluate, promote, and compensate people
without regard to any legally protected status, including race, color,sexual orientation, gender identity, age, religion, and disability.
We also observe all local non-discrimination regulations.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q&A
Q I am a manager and during a businessdinner, an employee made flirtatious
remarks to a vendor’s representative.
The representative did not seem tomind, and it was outside of the office.
Should I have said something?
A Yes, you have a duty to counsel theemployee on appropriate businessconduct. You should not assume thatthe representative is okay with suchtreatment; and your employee must
treat the representative with respect
regardless of the meeting location. When
you tolerate the inappropriate behavior,
you send the message that it is okay.

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Maintain a healthy andsafe workplace
Safe work practices
No production goal, cost saving, or competitive advantage isworth an injury or illness. Our Company’s occupational safety
standards and guidance are based on industry best practices,and our workplaces meet or exceed applicable occupationalsafety and health regulations. Our Company regularly conducts
reviews of our facilities and audits our safety practices. You
can do your part by following safety and health requirements
and promptly reporting any workplace accidents, injuries,
illnesses or unsafe conditions (including “near misses”).

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Q&A
Q A safety guard on one of our machines
is broken, but I was told that we do nothave the budget to have it repaired. Whoshould I ask about this?
A Speak up and report the issue to your sitemanager, your safety lead or Ethics andCompliance. Protecting our employees
is a priority, so do your part to make surethat equipment is functioning safely.
Q My manager suggested that we alter ournormal practices to speed up the production
line, but I do not think the new process issafe. What should I do?
A Never compromise when it comes to safety.
Contact your site safety lead or Ethics andCompliance, so that a safe course of action
can be determined.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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2.0 Weeach otherNo violence in the workplace
Acts or threats of violence interferewith our commitment to a healthyand safe workplace and are nottolerated at our Company.
Every employee has a responsibility to:· Report behaviors that threaten

or harm employees in a violent,or potentially violent, manner.

· Refrain from making jokes
about harming others.

· Call local law enforcement if you, or

someone you know, is in immediate
danger (if it is safe for you to do so).

· Never possess weapons, including
firearms, knives or clubs, whileon Company premises, including
Company parking lots, except
where otherwise required by law.

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A drug-free and alcohol-freeworkplace
Being under the influence of drugs or
alcohol will create safety hazards, put
you and others at risk and negatively
affect job performance. Never engage inwork if you are under the influence of any
substance. Also, do not possess controlled
substances, drugs or drug paraphernalia(other than lawful prescriptions) while on
Company premises, in Company vehicles
or performing work-related tasks.
In certain instances, you may be permitted
to drink alcoholic beverages at Company
events, or while conducting Company
business. When doing so, you must exercise
both moderation and good judgment, as
well as comply with applicable laws andCompany policies. Alcohol use is neveran excuse for inappropriate behavior atwork events. Do not drive if you cannot
operate a vehicle safely and legally.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q&A
Q My team went out for afterwork drinks and my manager
acted in a way that mademe uncomfortable. She
may have had too muchto drink because she
has never acted this way
before. What should I do?
A Report the incident to
Human Resources or Ethics
and Compliance. If yourmanager’s conduct madeyou feel uncomfortable, you
should let someone know.

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Ensure fair
employment practices
Our Company values our employees and engages in ethicallabor practices in our global operations and facilities.

· We forbid the use of child labor, forcedlabor or physical punishment.

· We follow applicable wage and hour laws, including
minimum wage, overtime and maximum hour laws.

· We respect our employees’ rights to lawful
freedom of association and recognize
their right to collective bargaining.

· We believe in equal opportunity for all employees.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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3.1 Maintain accurate books
and records
3.2 Avoid or disclose conflictsof interest
3.3 Appropriate gifts andentertainment
3.4 Protect and use Company
assets responsibly
3.5 Communicate about our
Company responsibly

3.0
We commit to
our Company
Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

3.6 Safeguard confidential
information
3.7 Protect the privacy of
personal data

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Maintain accurate
books and records
Honesty in our books, records andfinancial statements is critical to our
success and to maintaining the trust of
our stockholders and other stakeholders.
You must be accurate, transparent,
prompt and complete when recording yourtransactions, including your timesheetsand expense reports. Only use Company
funds for the purpose described in the
documents supporting the payment.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Ensure the integrity of financial reports· Follow internal processes, and the laws and rules
governing financial accounting/reporting, toaccurately record assets, liabilities, revenues andexpenses.

Q&A· Be honest when making forecasts and ensure that ourQ I informed my manager of errors in a reportthat we are submitting to a government agency.
He told me not to worry because ‘everyone
does it that way.’ Should I correct the errors?

· Disclosures we make to government entities andA Never knowingly allow inaccurate information
to be submitted to a government agency.
Speak up and report your concerns to
the Ethics and Compliance team.

· Never intentionally delay recording transactions.
reports accurately reflect our financial position, as describedby the supporting documentation.
communications to the financial community must be
full, fair, accurate, timely, and understandable.

Cooperate with auditors
Be open and honest with our internal and external auditors,
tax authorities, and other regulators. Do not take any action tocoerce, manipulate or mislead anyone auditing or reviewing ourCompany’s financial statements.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q My co-worker asked me to punch histimecard for him. What should I do?
A Timecards are Company records and mustbe punched by the employee, not a coworker. Advise your co-worker to speak
to his manager if there is an issue, but
do not punch the timecard for him.

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Avoid or disclose
conflicts of interest
We must always act in the best interest of
our Company. A conflict of interest occurs
when you are involved in a relationshipor activity that affects your objectivity inmaking business decisions. It is not possible
to list every type of conflict of interest
situation, so we rely on you to disclose
any situation that is, or could appear be,a conflict of interest. We can then assess
the facts and address the situation.

Q&A
Q My partner started an online
business to sell her homemade
candles. Is this okay?
A Perhaps, depending on thespecific details of the activity
and your responsibilities at
our Company. Regardless, thissituation could appear to be a
conflict of interest. Therefore,
you should discuss it with yourmanager or Human Resources.

Common conflicts of interest situations,and related guidance, can be found below.

· Investments· Family and personal relationships· Contacts with competitors,

suppliers, vendors or customers· Other employment· Board of Directors

CLICK FOR
ADDITIONALGUIDANCE· Personal Gain

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Appropriate gifts
and entertainment
Gifts and entertainment can promote positive professional relationships.
However, we must ensure that there is no appearance of an improper
attempt to influence business decisions associated with such activities.
When giving or receiving a gift or entertainment neither party should
feel that they must do something in return for the gift or entertainment.
Any gift or entertainment provided in connection with your job mustbe transparent and recorded accurately in our books and records.
Your expense report must include the purpose of the expense andthe person to whom you gave the gift or entertainment. Gifts tobusiness partners must be recorded as gifts from the Company.
If you have questions about gifts or entertainment,
review our gifts and entertainment policy below or
ask your manager or Ethics and Compliance.

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Q&A
Q I received a gift from a vendor that is valued at $150, so it
does not meet our guidelines. However, I do not believethat accepting the gift is inappropriate. What should I do?
A If you believe that an exception is appropriate, contact
Ethics and Compliance to request a waiver. Otherwise,
you should return the gift and explain that our policy does
not allow you to keep it. If you are not sure how to returnthe gift, talk to your manager or Ethics and Compliance.
Q One of my suppliers sent me tickets to a golf
tournament. What should I do?
A You can accept the tickets if: you are not obligated to treat
the supplier favorably in return for the tickets; a businesspurpose is served (i.e., the supplier will be attending
with you); you only occasionally accept tickets from the
supplier; and the tickets were purchased at a reasonable
price. If any of these conditions are not met, speak to yourmanager or Ethics and Compliance before accepting.

GIFTS ANDENTERTAINMENTPOLICY

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Protect and use Company
assets responsibly
Company property and equipment
Our Company provides you with the physical and electronic
resources you need to do your job. These resources are valuable
Company assets, and we trust you to use them appropriately
to conduct Company business. You must also protect our
Company assets from theft, loss, damage, unauthorizedaccess, waste and abuse. Promptly inform your manager aboutproperty or equipment that is unsafe or needs to be repaired.

Social media
Social media tools such as blogs, wikis, chatrooms and networking
sites provide a valuable outlet to communicate about our
Company. However, you must be responsible when using social
media and be careful when communicating about our Company.
Unless you are explicitly authorized to speak on behalf of ourCompany, make it clear that your views are your own and do
not reflect our Company’s position. When required by applicablelaw, disclose your affiliation with our Company. Review the
Newell Brands Social Media Policy for additional information.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Information Technology

Company records

Information Technology such as hardware, software, e-mail,and intranet/internet access are Company property. We rely
on you to use these electronic assets appropriately and toprotect our systems from malicious actors and downtime.

Records we generate during the normal course of businessare important Company assets. We must ensure that we canaccess these records if needed, including to comply withregulatory requirements. You are responsible for retaining,
storing and disposing of Company records properly andin accordance with our Records Retention Policy.

· Never install unauthorized software, applications, hardware
or storage devices on your Company issued computer.

· Do not use unauthorized physical or cloudstorage for Company information.

· Do not access our network throughunauthorized applications or devices.

You will be notified by the Legal team if you are required to retain
documents that relate to an ongoing litigation, investigation
or audit. Never dispose of information that is subject to alegal hold until the Legal team provides you with written
authorization to do so. Records that have met preservationand legal hold requirements should be properly discarded.

· Do not access, store, send, post or publish

material that is inappropriate, discriminatory,
sexually explicit, offensive or threatening.

Where legally permitted, we reserve the right to monitor the useof these resources.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Communicate about our
Company responsibly
Only individuals authorized in writing by Corporate Communications may
communicate to the media or publicly on behalf of Newell Brands. All
requests for information about Newell Brands from the media should be
forwarded to Corporate Communications and from analysts and investors
should be forwarded to Investor Relations. If you see social media content
that should be addressed by the Company, do not address it yourself,
rather send the relevant information to Corporate Communications.
Review the Newell Brands Media Policy for additional information.

Q&A
Q I received a call from a reporter
asking me to comment
on a project I’m working
on. What should I do?
A You may know the project better
than anyone else in our Company,
but if you are not specificallyauthorized by Corporate
Communications to speak to
the media about the project,
you should refer the reporter toCorporate Communications.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Safeguard confidential
information
Confidential information about our Company makes us who weare and drives our competitive advantage in the marketplace.
Information is confidential if it is not generally known to the public,
but you are exposed to it as part of your job. We count on you
to protect our confidential information so that it is not used for
improper purposes. Your obligation to protect Newell Brands’
confidential information continues even if you leave our Company.
Safeguarding our Company’s confidential information does
not prevent you from providing information to government
authorities regarding misconduct, participating in investigations,giving required testimony in proceedings regarding Newell
Brands’ conduct, or engaging in activities protected under thewhistleblower statutes administered by any government agency.

Protect our intellectual property
Preventing the unauthorized use of our intellectual property
protects our market advantage and helps grow our brands andour reputation. To the extent permitted by law, all intellectual
property conceived, created or made during the course ofa Newell Brands employee’s work belongs to our Company
and should be disclosed to the Legal team before you shareit with third parties. You must use Newell Brands’ intellectual
property in accordance with our Company’s ownership rights.

commit to our
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How can I protect confidential information?
· Use it only as necessary to do your job.
· Information may be confidential even if it will later

become public (e.g., financial results). Treat thisinformation as confidential until authorized Company
representatives have disclosed the information publicly.

· Share it only with Company employees who need toknow it to do their jobs and third parties who havesigned nondisclosure agreements or who are subject toprofessional duties of confidentiality (e.g., attorneys).

· Safeguard confidential documents, including in your office.
· Do not discuss Company business in public
places where others can hear it.

· Do not view confidential information on your laptop
in public places where others can see it.

· Only allow people with proper authorization into our facilities

and contact local security if you notice unauthorized visitors.

· Ensure that employees return all confidential information
if they leave our Company.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Protect the privacy of Personal Data
We believe that respecting the privacy of our employees, business partners and consumers
builds trust and long-lasting relationships. As part of your job, you may handle the Personal Dataof your colleagues, customers and consumers. Personal Data is information that can be used
to identify an individual directly or indirectly. Examples include: name, location, phone number,email address, photography, identification numbers, payment information and IP address. When
we collect, access or handle the Personal Data of our employees or third parties, we mustcomply with all applicable data privacy laws and the Newell Brands Global Data Privacy Policy.

How can we ensure we comply with data privacy regulations?
· Do not collect more Personal Data than is needed.
· Use Personal Data for a specific purpose, and only for that purpose.
· Do not retain Personal Data longer than needed anddelete it as soon as feasible.

· Limit access to Personal Data to necessary individuals.
· Send Personal Data securely and never to a personally owned device.
· Only allow a third party to access Personal Data that belongs to ourCompany for purposes that directly support Newell Brands.

· Consult with the Legal team before transferring data outsideof the country in which it is collected.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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commit to doing
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4.1 Engage in fair dealing
4.2 Ensure product safety
4.3 Avoid insider trading
4.4 Comply with competition laws
4.5 No bribery
4.6 Prevent money laundering

4.0
We commit to
our marketplace
Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

4.7 Comply with trade compliance laws

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Engage in fair dealing
Our Company believes that promoting positive business
relationships rooted in truth and transparency build long-lasting
relationships. We all must deal fairly and honestly with all third
parties, including customers, competitors and suppliers.

· Make sure that you are accurate in promotional
materials and can substantiate any claims
that you make about our products.
· Buy and sell based on appropriate businessconsiderations such as quality, price, service,reliability and ethical standards.

· Give potential suppliers and vendors equalconsideration, treating them fairly and honestly.

· Gather competitive information legally, ethically andin a way that will not reflect badly on our Company.

· Ensure that you are not infringing upon the valid
intellectual property rights of any third party.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q&A
Q We recently hired a Marketing Director whose previous
employer is a competitor of ours. During a team meeting, mycolleague asked the new hire to disclose information fromher previous employer’s marketing plans. What should I do?
A Speak up and tell your colleague that her request is
improper. If you do not feel comfortable addressing yourcolleague, report the matter to your manager or Ethics
and Compliance. Remember, we do not hire an employee
of a competitor to obtain confidential information.
Furthermore, we cannot ask colleagues to disclose
confidential information about their former employers.
Q Is it okay to refer to documents I havefrom a previous employer?
A It depends. If the documents contain confidential
information, you cannot use or share them with Newell
Brands. You must honor your confidentiality obligations,
including any nondisclosure agreements, with your prioremployers. If you have questions, ask the Legal team.

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Ensure product safety
Our consumers rely on us to make high quality, safe
products that consistently meet or exceed our Company’s
high standards. To maintain their trust, you must comply
with applicable consumer laws, as well as our Company’s
policies addressing the safety and quality of our products.
We must promptly address issues with products that do notmeet our high standards. If you have concerns about thequality or safety of our products, speak up and report them
immediately. Similarly, if consumers express such concerns,
forward them to the Legal team. If you are aware of a supplier
not upholding a commitment to quality and safety, speak up
and report it to our Corporate Social Responsibility team.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Avoid insider trading
We may have access to material, nonpublic (“inside”) information about our
Company, or companies with which
we do business. Material non-public
information is information that is not
generally known to the public and thata reasonable investor would consider
relevant in making investment decisions.
Insider trading occurs when someone uses
inside information to gain profits or avoid
losses in the stock market. Insider trading
is illegal. To comply with the law, neverbuy or sell stock or other securities on thebasis of inside information or provide “tips”
based on inside information to others.

commit to
3.0 Weour Company

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What are examples of potential“inside” information?
· Projected future earnings or losses· Undisclosed financial results· Planned mergers or acquisitions· Sale of Company assets
or subsidiaries· Changes in dividend policy· Changes in executive management· Significant new product plansor commercial strategies

Q&A
Q I work for Newell Brands andmy brother asked if he should
buy our stock. Because of myposition, I learned that we will
announce a new acquisition
which may increase the value of
our stock. What should I do?

financial problems

A Do not share this “inside”
information with your brotheror provide him with a “tip” thatwould influence his decision tobuy the stock. If you do, both ofyou would be breaking the law.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Comply with competition laws
We embrace a free marketplace where we compete vigorously and comply with competition
and antitrust laws. Competition laws exist in virtually every country and cover many types ofactivities. The intended purpose of competition laws is to protect consumers and companies
by preserving open competition. The penalties for violating these laws may include highfines, not being able to enforce commercial agreements and even imprisonment.

Relationships with competitors· Do not discuss sensitive business information with competitors including:pricing, sales terms, marketing plans, trade programs, discounts, boycottsof third parties, or proprietary information.

· Do not come to an understanding with a competitor about

any competitive matter, including refraining from competingin certain product or geographic markets.

· These types of discussions or agreements may give the appearanceof cooperating with competitors instead of being independent.

Q&A
Q I attended a trade association
meeting and during a break
one of the participants wanted
to compare the pricing andrebate programs that ourcompanies offer customers.
What should I do?
A If this person is attending a
trade association meeting withyou, he is likely employed by acompetitor. Advise him that you
cannot discuss this information
with him. You should neverdiscuss pricing or price-related
programs with competitors.

Terms of sale
You must not participate in agreements or policies that restrict our buyers’ resale
prices or terms and conditions of sale without legal advice. In countries where ourCompany has a particularly strong position, consult with the Legal team to ensurethat actions related to pricing and selling are not in violation of competition laws.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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No bribery
We are committed to conducting business with integrity and do nottolerate any form of bribery or corruption. As a global company, wemust comply with the laws of multiple countries as they relate tobribery of both private individuals and public/government officials.
Many of these countries’ laws, including the Foreign Corrupt Practices
Act, apply to conduct both inside and outside of the respective
country. Violations of anti-bribery laws can result in lawsuits,
substantial fines and jail time for both the Company and the employee.

· Never accept or provide anything of value in exchange

for an improper advantage or to obtain/retain business.

· Regardless of local practice, make sure you

avoid even the appearance of doing something
improper to gain a business advantage.

· Be particularly cautious when dealing withgovernment or public officials, officials ofinternational organizations and political parties.

· Do not give anything of value to a government

official or employee without obtaining priorauthorization from Ethics and Compliance. The term
“government official” should be applied broadly.

· Review our Anti-bribery and Anti-corruption

Policy to understand your responsibilities incomplying with relevant regulations.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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No facilitation payments
Our Company prohibits making facilitation payments. Facilitation
payments are payments made to government officials inorder to expedite official, routine government services.
If you need to make a payment in order to protect
your personal safety, notify Ethics and Complianceand Global Security if it is safe to do so.

We are accountable for our third parties
We are responsible for third parties and other agents acting
on our behalf. You must not knowingly allow a third party
to engage in corrupt practices, including making improper
payments, on our Company’s behalf. Additional information
about when and how to conduct due diligence on third parties
can be found in our Anti-bribery and Anti-corruption Policy.

Q&A
Q A Customs office outside of the U.S. is holding a large
shipment of our products because there was an error in
our paperwork. The Customs examiner asked our customs
agent to pay a small cash “fine” in exchange for releasing
the product. Can we permit our customs agent to makethe payment?
A No, you must obtain pre-approval from Ethics andCompliance. If it is not reviewed and documented
properly, making a payment to a government
official in exchange for the release of our products
could be a violation of our Code and the law.
Q I have a shipment that must be delivered in a week, but
was informed by the Customs office that it will take atleast three weeks to process the paperwork. Our logistics
vendor said that they can ensure delivery within a week.
Can I use the vendor to handle the delivery?
A Perhaps, but you must first ask the vendor questions
related to the methods that they will use to have thepaperwork processed more quickly. You should consult
with Ethics and Compliance to confirm that you are asking
our vendor all of the appropriate questions.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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commit to doing
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Prevent money laundering
We abide by all laws designed to deter money laundering. Moneylaundering is the process by which funds generated through criminal
activity (e.g., terrorism, drug trafficking) are moved through legitimate
businesses in order to hide their criminal origin. Never knowingly
facilitate money laundering and only conduct business with third
parties after you have conducted appropriate due diligence.

Be aware of suspicious transactions· Payments in cash
· Requests to transfer funds to/from countries or entities
that are not related to the transaction or customer· Payment terms that are inconsistent with ourCompany’s normal terms of business

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

Q&A
Q A customer asked me to divide
a $10,000 transaction into four
payments so that he can avoid
having to complete paperwork
required by the government. Whatshould I do?
A Advise the customer that you will not
split the transaction because it is aviolation of our Company’s policy.
The transaction must be processed
for the total amount with all required
paperwork submitted to thegovernment. Also, report the request,
and any suspicious transactions,
to Ethics and Compliance.

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Comply with tradecompliance laws
As a multi-national company our transactions often involve moving
products across national borders. Trade is heavily regulated, andmany governments set rules and regulations to control importing,exporting, and related activities. We must comply with these laws
and regulations that govern international trade. Violations of export
and import laws can result in severe civil and criminal penalties
for the Company and its employees, including imprisonment.

· Export controls restrict or prohibit exports tocertain countries, individuals, and entities.

· We are responsible for ensuring that, at a minimum, ourtransactions are compliant with U.S. sanctions laws.

· If you know, or have reason to believe, that abusiness partner intends to improperly resell our
products, for example in a country that is subject
to sanctions or to a third party that is targeted bysanctions measures, notify Ethics and Compliance.

Q&A
Q A third party asked me if he could distribute our
products in Iran. The distributor is based in Iranand appears on the U.S. government Specially
Designated Nationals list. Since the products
are not manufactured in the U.S., I work outsideof the U.S. and I am not a U.S. national, is it ok
for me to sell our products to this distributor?
A No. As a U.S. company, we must ensurethat our transactions are compliant with
U.S. sanctions laws, regardless of where an
employee is located. If you have any questions,contact the Ethics and Compliance team.

· We are prohibited from participating in any international
boycott that is not sanctioned by the U.S.

· Review the Newell Brands International Export

Compliance Policy for additional information oncomplying with anti-boycott and export regulations.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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5.1 Protect our natural environment
5.2 Source responsibly
5.3 Contributions

5.0
We commit to ourcommunity
Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Protect our natural environment
Environmental Regulations
Environmental laws protect people and the planet and aid in the preservationof valuable natural resources. Compliance with these regulations protect
against harmful impacts to the communities in which we operate and reducesrisks to the Company and our employees. Violations of environmental laws
may result in high fines, expensive and long-term remediation obligations,
restrictions on our operations, injuries to people, and even imprisonment.

· Compliance with laws and regulations is the minimum standard.
· Comply with our corporate environmental standards, which are applicable
to all of our operations and ensure uniform practices around the globe.

· If you are unsure about specific requirements,
contact the Environmental Affairs team.

Sustainability
As responsible corporate citizens, we strive to protect our national environment andreduce the environmental impacts of our operations. We incorporate sustainable
practices into our operations to reduce our use of the planet’s valuable resourcesand our impacts on the environment. These practices include waste reduction anddiversion; water conservation; energy conservation; the reduction of greenhousegas emissions; and the efficient and thoughtful use of materials in operations,products, and packaging. We hold ourselves accountable for implementing
these practices by setting public, company-wide sustainability goals.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Source responsibly
Our responsible sourcing program, which includes both social
compliance and supply chain security, aims to increase transparency
across our supply chain so we can ensure our customers andconsumers receive high-quality and ethically produced or sourced
products. Our Vendor Code of Conduct reflects our expectationthat third parties adhere to our rigorous standards on human rights,
individual workers’ rights, and to all applicable laws. We comply withlegislation focused on eliminating slavery and human trafficking
from global supply chains, including the UK Modern Slavery Act andCalifornia Transparency in Supply Chain Act. Our Company does
not permit our business partners to use inhumane labor practices,
including forced, compulsory and child labor or physical punishment.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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Contributions
Charitable Contributions
As a global company, we take seriously our responsibility to give back to the communities inwhich we operate. We are committed to making the world a better place and support nonprofit
organizations whose missions align with our business, Values and philanthropic priorities.

· We are uniquely positioned to make a difference through in-kind donations of Newell
Brands’ product, particularly in response to natural disasters and other crises.

· We encourage employees to give back through volunteerism.
· Through the Newell Brands Charitable Foundation’s Local Impact Grant Program,
employees can nominate and vote on nonprofits to receive funding.

· The Foundation’s Matching Gift Program allows employee donations to selectcharities to be matched dollar-for-dollar by the Foundation, up to a certain limit.

· Prior to committing a donation on behalf of the Company, review the Newell Brands
Philanthropy Policy and follow the process required for review and approval.

Political Contributions
As a matter of policy, we do not use corporate funds to make contributions to support
or oppose federal, state or local political parties, candidates, campaigns, ballot
measures, political organizations, or social welfare organizations. Any contribution ofCompany funds or assets for these purposes requires approval by the Chief Executive
Officer. Review our Government Affairs Policy for additional information.

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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If you have a question or concern, speak up by reaching out
to your manager or any of the resources listed below.

Resources

Contact Information

Ethics Hotline

Report Online: Click here.
Toll-free Call: Follow the dialing chart found here

Global Ethics and Complianceethics@newellco.com

Chief Ethics and Compliance Officer

Kellye.Gordon@newellco.com

Chief Legal Officer

bradford.turner@newellco.com

Legal Teamlegalservicesdepartment@newellco.com

Audit Committee

For reporting accounting, financial controls, or related issues, mail asealed envelope marked "To Be Opened by the Audit Committee" to:6655 Peachtree Dunwoody Road
Atlanta, GA 30328 USA

Corporate Communications

media@newellco.com

Corporate Social Responsibility Team

matthew.hamilton@newellco.com

Environmental Affairs

environmental.compliance@newellco.com

Global Security

security@newellco.com

Human Resources

Contact your local Human Resources Business Partner

Investor Relations

investor.relations@newellco.com

Trade & Customs Team

RPS@newellco.com

Have a question or concern? Speak up, we’re listening at Ethics Hotline or ethics@newellco.com

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