Responsible
Sourcing
ManualBetter together.

CONTENTS
0. INTRODUCTIONS
A. ADMINISTRATIVE PROCEDURES
B. SOCIAL COMPLIANCE AND SUPPLY CHAIN SECURITY AUDIT PROCESS
C. CAPACITY BUILDING AND CONTINUOUS IMPROVEMENT
D. CORPORATE CITIZENSHIP
E. VENDOR CODE OF CONDUCTF. SUPPLY CHAIN SECURITY GUIDELINES & ISSUE TOPICS

CLICK ON ICONSTO GO TO PAGEC.

Capacity
Building And
Continuous
Improvement

B.

Introductions

A.

Administrative
Procedures

SocialComplianceand Supply
Chain Security
Audit Process

D.

E.

F.

0.

Corporate
Citizenship

Vendor Codeof Conduct

Supply Chain
Security
Guidelines &Issue Topics

0

Introductions

3

Better Together
Introducing Newell Brands, a house of leading brands that’s somuch greater than the sum of its parts.

LEARNING & DEVELOPMENTKEY BRANDSWRITINGBABYHOME & COMMERCIALKEY BRANDSHOME FRAGRANCECOMMERCIAL

FOOD

HOME APPLIANCESOUTDOOR & RECREATIONOUTDOOR & RECREATIONKEY BRANDS

0Introductions

4

Introductions
The purpose of our Responsible Sourcing Manual is to ensure
our suppliers fully understand our Social Compliance andSupply Chain Security requirements and to assist suppliers with
the implementation of our requirements in factories that are
producing Newell Brands’ products. This manual was developed
to provide comprehensive guidance of our requirements and will
provide you with all of the necessary information needed to raise
and maintain your factory’s standards.
Transparency and Supplier Development are key attributes to
our Social Compliance and Supply Chain Security programs. We
look forward to your active engagement and participation.

INTRODUCTIONS

It is the expectation that suppliers will comply with theguidelines and requirements outlined in this manual. Failure tocomply can result in termination of our business relationship.
To report any ethics or compliance concerns or any improper
behavior from a Newell employee or 3rd party auditor please
access this website (https://secure.ethicspoint.com/domain/
media/en/gui/52773/index.html) to obtain the ethics hotline
phone number for your country or email us at:
Ethics@newellco.com
Newell Brands is dedicated to achieving carbon neutrality
for all direct operations (scope 1 and 2) by 2040. Our 2023
Corporate Citizenship Report, scheduled for release in 2024, will
include a disclosure of our baseline emissions. Additionally, weplan to create a scope 3 footprint that will outline emissions
across our value chain, including all suppliers, in 2024. Uponcompletion, we may establish a scope 3 emissions reduction
goal. As a supplier to Newell Brands, we will be reaching out torequest emissions data to assist us in developing this footprint.
Further communication will be provided in 2024. We are
excited to collaborate with each of our partners to gain a better
understanding of our impact and opportunities to safeguard
people and the planet.

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Administrative procedures

5

Administrative
Procedures
Our Administrative Procedures play a crucial role in the
successful achievement of all linked pertinent processes toachieve compliance. Such procedures should facilitate our tasks,
and should bring the coordination and cooperation needed to
fully incorporate.

Vendor Code of Conduct
Compliance
All suppliers must review and acknowledge compliance with the
Newell Brands Vendor Code of Conduct (VCOC). Annual certification/recertification on VCOC is required by Newell Brands’ policy for all
new and/or existing suppliers. Newell RS team conducts annual
supplier training to review VCOC. The current version of VCOC isavailable at: https://www.newellbrands.com/ethics-compliance

Social Compliance
Selection and Supply Chain
Security Criteria
The selection process for our suppliers has been set up to integratesocial compliance standards with the supplier pre-qualification andapproval process to further drive performance and to help sourcefrom suppliers that pose the least amount of risk to our organization.
It is the responsibility of the supplier to remediate all findings
identified during the Newell Brands Social Compliance and Supply
Chain Security Self-Assessment prior to the official audits
taking place.
Once internal teams complete a supplier profile and if they want to
pre-qualify a supplier, the initial documents will then be distributedby the Social Compliance and Supply Chain Security team. Upon
receipt of said documents, these documents will be reviewed andaudits will be scheduled based upon sourcing needs.

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1

Administrative procedures

Review
Program Materials

2

3

6

Identify Areas of
Improvement andmake necessary
improvement prior
to audit

Take Newell Brands
Social Compliance andSupply Chain Security
Self Assessment

45Participate in
Audit

Complete
Corrective
Actions

6

7

Annual Assessment

Resolve Issues

Escalation Process
The Escalation Process is in place to identify the people to contact in the event of an incident at a factory or for a supplier’s
low audit rating. In the event that a supplier receives an “F” rating or its equivalent or a Zero Tolerance rating or its equivalent,
notifications will be sent internally to the Newell Brands teams that are involved with the particular supplier. Based upon theaudit score, suppliers may be required to take mandatory capacity building projects which include training at their expense. In
the event of a Zero Tolerance violation this will be escalated to the Newell Brands Zero Tolerance committee and if the findingis substantiated, our business relationship will be impacted and will most likely result in loss of business and termination of ourbusiness relationship.

Audit SchedulingUpon receiving the required documents, the Responsible Sourcing (RS) team will make an assessment of the factory’s
compliance infrastructure and based upon sourcing expectations, an initial onsite Social Compliance and Supply Chain
Security audit will be scheduled.
When an audit is scheduled, the factory will be notified of the audit date. If the audit cannot be conducted on the requested
date, the factory must provide the RS team with a written statement within 48 hours briefly describing the reason(s) for theunavailability and a reasonable one-week window for rescheduling the audit.
After an audit date is confirmed, any request for an audit cancellation must be sent directly to the RS team.

Audit-Related Payment Process
Suppliers will be responsible for all costs associated with compliance. The costs include but not limited to the audit payments
made to 3rd independent service providers.

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7

Audit Result and Corrective Action
After the audit is completed, a Corrective Action Plan (CAP) will be provided to the supplier. Each CAP will highlight the audit
findings and provide recommended corrective action(s). The supplier must complete the recommended corrective action(s) tohave the issues resolved. The severity of the findings will dictate the timing for resolution of the findings.

Zero Tolerance Policy
Newell Brands takes human rights and responsible sourcing practices very seriously and we expect each of our suppliers tomaintain similar commitments to human rights and responsible sourcing. As such, in order to engage in business activity with
Newell Brands, all suppliers are required to agree and abide by our Vendor Code of Conduct.
There are certain violations that Newell Brands and our Customers deem as zero tolerance offenses. These types of violations
will not be tolerated in any Newell Brands audits or audits from our Customers, including all audits that may be conducted onyour factory such as Social Compliance, Supply Chain Security and Quality. If these types of violations are identified, our teamwill launch an investigation to validate the findings. If a zero-tolerance violation is validated, our business relationship will be
impacted and will most likely result in loss of business and termination of our business relationship.
Factories are expected to have effective management systems in place to manage social compliance actively within their factory
and to ensure there are no zero tolerance violations present. Factories also must ensure there are no banned materials present inour products and that there is no sourcing taking place in sanctioned countries or regions. The below violations are deemed aszero tolerance. Please ensure your entire factory is aware of Newell Brands stance on zero tolerance issues, what zero tolerance
issues are and that you ensure your factory is in full compliance to these requirements.

Newell Brands Zero Tolerance Violations as defined in
the Newell Vendor Code of Conduct:
•
•
•
•
•
•
•

Child Labor
Forced or Prison Labor
Bribery attempts of any form
Discrimination
Harassment
Corporal Punishment
Unauthorized Subcontracting

•
•
•
•
•
•

Falsified documents
Denial of AccessCircumvention of audit process
Wastewater discharge into the environment without treatment
Contraband contents in shipping Container
Cross Border Smuggling

In addition to zero tolerance issues, if we find repeat violations or systemic issues in your factory, we may choose to terminate ourbusiness relationship. Our customers may also prescribe additional violations, in which case you may be subject to deactivation,
termination, and/or even financial penalty. It is the supplier’s responsibility to ensure they are proactively managing risk andunderstand the program requirements of Newell and our Customers.

Audit Scope
In order to build a healthy and smooth supply chain base for continuous supply of products to our valuable customers, Newell
Brands arranges RS and SCS assessments at all suppliers, including suppliers who make components, raw materials and 2nd tiercontractors. Suppliers are required to disclose and/or update all these related production locations

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Administrative procedures

8

Audit Guidelines
Social Compliance and Supply Chain Security : Audit Criteria and Scheduling
Newell Brands and its affiliates have adopted a comprehensive Social Compliance and Supply Chain Security Program
to ensure operation within the highest standards of business ethics and in accordance with all applicable laws andregulations. Our commitment to enhance responsible sourcing will support protecting employee safety, employee health,
the well-being of the global community and the integrity of our supply chain.

Supplier Selection Process:The selection process for our suppliers has been set up to integrate social responsibility standards with the supplierpre-qualification and approval process to further drive performance and to help source from suppliers that pose the least
amount of risk to our organization.
All new suppliers are required to review and acknowledge compliance with the Newell Brands Vendor Code of Conduct. A
Self-Assessment is to be completed within 10 working days of receiving the document. It is the responsibility of the supplier
to remediate all findings identified during the Newell Brands Social Compliance and Supply Chain Security Self-Assessment
prior to the Social Compliance and Supply Chain Security audit.

New suppliers are required to sign agreement to becomplaint with US-CBP CTPAT standards
New Suppliers
All new suppliers must have initial Newell Brands Social Compliance and Supply Chain Security Audit conducted to ensure
suppliers that are producing products for Newell Brands are abiding by the requirements outlined within the Newell Brands
Vendor Code of Conduct. Suppliers must have a valid business license and comprehensive financial health verification
prior Newell issuing business to a new supplier.
In addition, it is expected that all Newell Brands suppliers either new or existing maintain all legally required documents
which include, but not limited to local governmental inspection reports and responses, health and safety related
certificates/permits, building certificates, local government environmental certificates/permits, etc.

Existing Suppliers
When developing audit schedules for existing suppliers, Newell Brands Responsible Sourcing team will apply a risk- based
audit approach. At a minimum every supplier will be required to participate in a Newell Brands audit every 24 months
regardless of prior rating.
Newell brand RS team and Newell customers maintain the right to conduct unannounced audits of any disclosed location.

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9

Audit Exemption Guidelines
The purpose of having Audit Exemptions Guidelines is to reduce redundant audits and allocate resources to supplier remediationand development.

All Suppliers
All shared industry audits accepted by Newell Brands are mapped to our Vendor Code of Conduct requirements and tied to anaudit rating. Only suppliers that are in good standing with an overall rating of “A”, “B” or “C” can provide a shared industry audit inplace of a Newell Brands Social Compliance Audit or a Supply Chain Security Audit. These audits shall be conducted by auditors
registered by the Association of Professional Social Compliance Auditors (APSCA), and at the expense of the suppliers. If a sharedaudit is approved the audit team will follow up on any corrective actions to ensure CAP closure and compliance. Suppliers are
only able to share an approved industry audit once every 12 months.
Suppliers scoring “F” will be required to go through the Newell Brands Social Compliance or Supply Chain Security audit process.
Suppliers will be held accountable for all fees associated with Newell Brands audit.
In addition to Newell Brands’ audit guidelines, other customers may require industry audits on an annual basis. Suppliers are also
responsible for covering the additional costs associated with customer audits.

Accepted Reports• Business Social Compliance Initiative (BSCI)• Better Work• Responsible Business Alliance (RBA)• International Council of Toy Industries (ICTI)CARE Program• SEDEX Members Ethical Trade Audit (SMETA)• Social Accountability 8000 (SA8000)• Worldwide Responsible Accredited Production (WRAP)• SCAN - Supplier Compliance Audit Network

Conditions of acceptance1

No zero-tolerance (No Exception) violations or
Immediate Resolution findings

2

Valid audit done in current calendar year orwithin 1 year period.

3

Supplier needs to provide Corrective Action
Plans for findings as instructed by Newell Brands
RS Team or SCAN audit team.

4

Supplier completes all required self-audit
questionnaires.

5

Newell Brands and our Auditors will conduct
onsite validation visits as needed to determine
completion of Corrective Action Plans.

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Administrative procedures

10

Audit Rating Definitions
RatingScore

A

90 -100
No or a few minor
issues identified,demonstrating highlevel of performance

Rating

Score

B

75-89

Major issue
identified, meetingmost of thestandards

Rating

Score

C

60-74

Multiple Major
issues identified,intervention needed

Rating

ZT

Critical issue
identified, strong
intervention needed

Zero Tolerance issue
identified

Score

F

Rating0-59

Refer to the “Social Compliance and Supply Chain Security Issue Topics” section
for further guidance related to audit item violations.
Follow-up audits for a “F” rating will likely occur within 6 months of the previous audit date, or as determined by Newell Brands.
Follow-up audits for “C” rating will likely occur within 12 months. Moreover, all audit determinations will be made on a case-by-casebasis based on the nature and level of non-compliance risks, the factory’s geographic location (high-risk, medium-risk, and lowrisk), the type of remediation in place, and the level of confidence in the particular supplier.

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11

Corrective Action Plan (CAP) Guidelines

Note: SCAN will administer the SCS CAPA’s with the RS team (NTC) overseeing progress

Violation Category

Violation Description

Recommendation

State violation category per
audit checklist

State the audit violation(s)The corrective action(s) required(recommendations from the auditor).

RatingFailure Analysis

Corrective Action Plan

State audit rating A / B / C / E / F per
audit checklist

Factory must provide root
cause of failure

The factory must include achievablecorrective actions that will be
implemented to resolve the noncompliance. The factory is required toprovide a multi-step plan detailing eachphase with specific deliverable andsuccessive target dates for correcting
violations that require some gradual or
extended period for a full remediation.

Responsible Person

Completion Date

Improvement Evidence(s)Enter person who is responsible forcorrective action of violation

Enter date of completion only when the
non-compliance is fully resolved

Submit supportive documentation(scanned copies, photos…) for a final
evaluation by Newell Brands.

Suppliers will be responsible for reviewing findings within Newell Brands compliance software system (Rizepoint) and /or via CAPs
provided by Newell RS team and submitting Corrective Actions accordingly.
All Critical findings are to be remediated with 60 days or less.

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Administrative procedures

12

Enablement on Continuous Improvement
If an audit rating is assessed with F or below, the supplier might be requested to go through a capacity building process inaddition to CAP completion requirement. Newell RS team will work with the supplier to determine the most suitable path forward
based on 1) impact on the affected workers, 2) nature and risk level of non-compliances, 3) business impact, 4) suppliers’
knowledge, capability, and resource availability, and 5) suppliers’ commitment level.
If external resource is deemed necessary to support with remediation process, which includes but not limited to capacity building
project taking, training event participation, E-Learning course taking, etc., the supplier is requested to bear all the cost related tosuch engagements as a commitment to improve performance and meet Newell’s expectation.
In general, suppliers’ factories are expected to improve the rating to at least C or above after the current phase of remediation/
capacity building process is completed. If repeated F ratings or worse were received, the factories would be considered fordeactivation, and potentially lose business with Newell and/or Newell customers.

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Social Compliance andSupply Chain Security Audit Process

13

The Following Steps
Make Up the
Audit Process:There are certain violations that Newell Brands deems as “ZeroTolerance.” These types of violations will not be tolerated andwill likely result in termination of our business relationship. All
vendors are expected to have effective management systems
and awareness training in place to manage social compliancewithin their respective factories and to ensure there are no zerotolerance violations present. Vendors must also ensure there
are no banned materials from sanctioned countries or regions
present in products sourced to Newell Brands. Vendor must
make their factories aware of zero tolerance issues to ensurecompliance with Vendor Code of Conduct requirements.

Pre-Audit
Questionnaire

Opening
Meeting

Factory
Tour GuidanceOn-site Report
Preparation

Document
Review

Workers
Interview

Closing
Meeting

Publication of
Audit Result

Follow-up
Audit

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Social Compliance andSupply Chain Security Audit Process

14

1. Pre-Audit QuestionnaireThis is a set of questions completed by the supplier that is used to familiarize assessors and our company with the Social
Compliance and Supply Chain Security practices and policies of the supplier. It is requested as part of the initial qualification of
the supplier, as part of a periodic update because the previous questionnaire is more than two years old, or because the audit
team feels enough has changed at the supplier since the last questionnaire to warrant a new one. The pre-audit questionnaire
must be returned to the RS team by the required date.

2. Opening Meeting
Opening meetings are conducted with the supplier’s top management and will entail introductions, a discussion on the pre-audit
questionnaire, completion of integrity letter and verification of factory business license.

3. Factory Tour Guidance
During the factory tour, Newell Brand’s auditor must be provided access and will visit all parts of facility, including but not limited to
production area, warehouse area, fire control area, chemical/hazardous substance placement area, waste storage area, dormitory
and canteen, packing, shipping, loading dock and cargo area, guard house, IT room, CCTV monitor system, seal locker, container
inspection records and tools, perimeter fencing and other sensitive areas.
During the factory tour visit, auditors will do the following:• Check whether the markings in production/warehouse are clear and reasonable; (e.g.: fire extinguisher location & label,
PPE location, material placement and label, forklift access etc.).
• Check whether exit routes or exits for fire evacuation are safe and compliant with fire control regulations.
• Check all facilities for fire alarms, emergency lighting, sprinkler systems, fire extinguishers, smoke detectors and whether
they are properly maintained and recorded.
• Check chemical/hazardous storage area to ensure the area is clear, chemicals are segregated, markings and storage aresufficient for the facility.
• Check the waste storage area to ensure it has clear marking, segregation area and disposal scheme• Check the dormitory and canteen including all facilities (washbasins and water taps, lighting, shower and toilets).
• Review security measures and emergency evacuation plans to ensure they meet fire control requirements.
• Check factory for adherence to all Minimum Security Criteria that align with Global SCS programs (CTPAT, AEO, PIP, etc.)

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Social Compliance andSupply Chain Security Audit Process

15

4. Worker Interview
Employee interviews are an integral part of the process used to assess the effectiveness of the Social Compliance processes in place.
All employee interviews will take place in a private area away from the production floor. No management or their representatives will bepresent. Employees to be interviewed will be selected by the audit team, not management for the supplier. This is normally done during
the walk-through but may be done at any time.

TIER

AUDIT PROTOCOLNUMBER OF WORKERS

WORKERS INTERVIEWS

1Regular Audit Protocol< 100

5 Employees at minimum

2

Regular Audit Protocol

101 to 200

10 Employees at minimum

3

Regular Audit Protocol> 200

25 Employees

5. Document Review
The auditor will review documents to assess the facility’s compliance with Vendor Code of Conduct. Documentation to be reviewed
includes but is not limited to the following:

Business
LicensePersonnel Files

Workers’
Contracts

Time Cards

A

B

C

D

Payroll
Records

Production
Records

Security
Records

Accident &Injury Records

E

F

G

H

Shipping Docsor Other Related
Records

I

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Social Compliance andSupply Chain Security Audit Process

16

6. On-Site Report Preparation
The auditor will collect information during factory tour, document review and worker interviews sufficient to identify, discuss anddocument the audit result during closing meeting.

7. Closing Meeting
A member of the manufacturing site management must attend the closing meeting. At the closing meeting, the audit team leader willsummarize the audit results, make recommendations for changes/improvements that may be needed and discuss any questions the
supplier may have. A member of supplier management must sign the audit results on the audit template and agree to develop and takecorrective action for any findings noted during audit.

8. Publication of Audit Results
Audit results will be shared with suppliers and Newell Brands’ internal teams. High risk findings will be put into our escalation process.

9. Follow-Up Audit
Audit will be scheduled to ensure findings have been resolved and factory has the appropriate management systems in place to meetcompliance expectations.

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Capacity Building And Continuous
Improvement

17

Capacity Building
And Continuous
Improvement
We strive to continuously strengthen and enhance our responsible
sourcing programs to ensure we mitigate risk, minimize negative
impacts, and make a positive contribution to the businesses,
people and communities we support through ethical businesspractices. To achieve it, we require all suppliers to embed spirits
of “Transparency” and “Continuous Improvement” into daily
compliance operation when working towards meeting Newell
Brands Responsible Sourcing requirements. On a commitment
to workers and to continuous improvement, we put the safety
and interests of workers first and work to strengthen suppliers’
capacities to manage and mitigate risks in their value chains. If anissue is found, we work with suppliers to remediate the issue byprioritizing worker feedback and offering resources to help theminvest in worker well-being and safe workplaces.
To help suppliers advance on the responsible sourcing journey,
Newell Responsible Sourcing (RS) team provides training andwebinars on topics that matter most.
Supplier training program focus on awareness building, bestpractice sharing, and continuous improvement supporting. The
goal is to ensure compliance with the Vendor Code of Conduct
and all related legal requirements. The trainings not only provide
important updates and guidance for suppliers to meet program
requirements, but also as an opportunity facilitate a two-way
communication between Newell Brands and our suppliers.

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Capacity Building And Continuous
Improvement

18

Training program is delivered with multiple formats. In addition to regular supplier training events, we hold webinar trainings andvirtual supplier roundtable meetings which are tailor made to address specific topics, such as effective management systemdeveloping, Newell’s customer standard refreshing, force labor preventing, etc. Over the time, we expect suppliers to take more
ownership and accountability managing compliance performance while continuously benefiting from training program. New
E-Learning and an online-based Academy are expected to be developed to enhance learning experience. The training materials
are shared on Newell Brands’ platform (Rizepoint).
Suppliers are mandatorily requested to attend the training under the circumstance listed below, but is not limited to:a. New supplier onboardingb. Strategic supplier capacity buildingc. Low performance supplier remediation supportingd. New initiative introduction and awareness buildinge. Special project engaging
f. All others requested by Newell RS teamManagement Action Plan (MAP)

When an audit reveals a critical issue or recurring failures that have gone unresolved with a supplier, a Management Action Plan (MAP) is required
to be implemented at the supplier’s expense. MAPs include close partnership with suppliers and key internal cross-functional stakeholders toensure that the supplier understands the root cause of the failure and makes changes to reduce the likelihood of recurrence. The program iscustomized for each supplier’s circumstances focused on the specific area targeted for improvement.
Newell expects all suppliers to make full commitment and take responsible ownership to achieve improvements during theremediation process. Newell RS team will provide guideline and support throughout the process. With critical issues, we
expect suppliers to show that meaningful progress towards remediation within a defined timeline is made, based on the issue.
Meanwhile we recognize that some long-standing issues may come with complicated reasons behind, such as on the issue ofexcessive working hours (OT), which takes time to effectively remediate. With full transparency in mind, suppliers are requested
to work on continuous improvement in a sustainable fashion. We believe a robust management system can support productivity
while assuring continued compliance with our Vendor COC requirements, therefore we encourage suppliers to make effort,
measure progress, and show impact on management system enhancement and workplace dialogue building.

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Corporate Citizenship

19

Newell’s Corporate
Citizenship
Newell Brands has adopted 9 areas of focus. Our corporate
citizenship philosophies guide our efforts to be a force for good andthe tangible ways we’re making a difference.

•
•
•
•
•
•
•
•
•
•

Diversity, Inclusion and Belonging
Employee Engagement
Sustainability Governance
Climate and Emissions Reduction
Energy Management
Waste Minimization and Diversion
Product and Packaging Lifecycle innovation
Human Rights and Responsible Sourcing
Community Outreach
Secure Supply Chains

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Corporate Citizenship

20

Newell’s Corporate Citizenship Philosophies.
Diversity, Inclusion and Belonging

Climate and Emissions Reduction

We believe diversity, inclusion and belonging are
critical to the success of our business and to helping
attract, retain and develop the best talent. A diverse
and inclusive workplace creates and environment richwith innovative ideas, and engage workforce and better
solutions. We are committed to building inclusive teams
that reflect the diversity of our brands and consumers.

Climate change is one of our society’s most pressing
issues and we aim to lower emissions across our value
chain. We’ve set GHG reduction, renewable energy,
carbon neutrality and waste reduction goals to minimize
our impact on the planet and people.

Sustainability GovernanceOur corporate citizenship approach is rooted in strong
leadership. We have instituted a Corporate CitizenshipCouncil with cross-functional senior leadership. The
Nominating/ Governance Committee of our Board of
Directors provides oversight of our programs and policies.

Energy Management
Energy is one of our largest impacts on the climate andnatural resources. We work actively with our sites toimprove efficient energy management, set reduction
goals and implement energy-saving projects.

Employee Engagement
Our people are our greatest asset and drive our successthrough their passion and commitment. Through ourcompany-sponsored programs, we encourage andsupport them to drive positive change across theorganization. We celebrate our Sustainability Champions
who are empowered to implement sustainability initiatives
at their locations and our give@newell Ambassadors who
help spread awareness of the many volunteer efforts andopportunities available across our organization.

Waste Minimization and Diversion
We are working to reduce waste to landfill and arecommitted to finding new ways to divert waste to moreproductive uses, including reuse and recycling.

Product and Packaging Lifecycle
innovation
Reducing the impact of our products and packaging is
critical to reducing the environmental impacts throughout
the life cycle of our products. We have developed
design for sustainability guidelines and set packaging
sustainability goals to source more sustainable materials
and reduce waste.

Secure Supply Chains
Newell Brands fully supports Supply Chain Security (SCS)
programs such as AEO, PIP and Customs-Trade Partnership
Against Terrorism (CTPAT). We recognize the critical role
they play in safeguarding global supply chains from potential
security risks.
We understand that SCS is an essential tool that helps
to identify and mitigate potential security threats andvulnerabilities, while also enhancing the efficiency of the
supply chain. We are committed to working closely with our
supply chain partners to ensure that all SCS requirements are
met and that the program’s standards are consistently upheld.
We recognize that formal SCS programs are a collaborative
effort, and we are committed to actively participating inthis effort to ensure that our supply chain partners, and ourorganization remain compliant and secure. We understandthe importance of our collective responsibility to maintain asafe and secure supply chain

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Corporate Citizenship

21

Human Rights andResponsible Sourcing

Community OutreachOur suppliers and their employees are an extension of
our team. We set stringent standards around ethicalconduct and safe working conditions that our suppliers
are required to meet. We also require our suppliers
to maintain high standards through ongoing training,assessments and engagement.

We have a responsibility to give back to the communities
in which we operate through philanthropy, volunteer
hours and in-kind donations. We are committed topartnering with nonprofit and give groups that align with
our values to create change locally, nationally.

Sustainability

Newell Brands is committed to ensuring that the most sustainable practices are used when sourcing materials and manufacturing our products.

We are focused on improving sustainability at each phase of our products’ development cycle from supply partners that share our focus onsustainability. Suppliers are responsible for monitoring their supply chain and are encouraged to incorporate our sustainability philosophies into
their culture and operations to ensure we all are making a better tomorrow.
Newell Brands is dedicated to achieving carbon neutrality for all direct operations (scope 1 and 2) by 2040. Our 2023 Corporate Citizenship
Report, scheduled for release in 2024, will include a disclosure of our baseline emissions. Additionally, we plan to create a scope 3 footprintthat will outline emissions across our value chain, including all suppliers, in 2024. Upon completion, we may establish a scope 3 emissions
reduction goal. As a supplier to Newell Brands, we will be reaching out to request emissions data to assist us in developing this footprint. Further
communication will be provided in 2024. We are excited to collaborate with each of our partners to gain a better understanding of our impact andopportunities to safeguard people and the planet.

Operations Goals

Newell strives to make decisions through the lens of sustainability to ensure we remain responsible environmental stewards by reducing energy
use and emissions, waste and our impacts on water and surrounding land of our facilities. Overall, we have set sustainability goals baseline andhave committed to achieve the following. By sharing our goals, we are encouraging our suppliers to set similar goals for themselves.

Reduce Scope 1 and 2
GHG emissions frommanufacturing by

30%(2016 baseline)

GOAL YEAR

2025

Divert90%

of manufacturing
waste from landfill

GOAL YEAR

2025

Use SmartWay-approved
carriers for over90%

Convert30%of ton-miles traveledin U.S.

of Newell’smanufacturing
electricity to renewably
produced electricity

GOAL YEARGOAL YEAR

2025

2030

Achieve carbon
neutrality for all
our Scope 1 and 2
emissions acrossour global portfolio
at all manufacturing,
distribution, warehouse,retail and office sites
GOAL YEAR

2040*To learn more about Sustainability at Newell Brands please check out our website at https://www.newellbrands.com/community/sustainability.”

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Corporate Citizenship22

Packaging Goals

Newell Brands is committed to responsible material choices and eliminating problematic materials from our packaging. In support, we set a
goal in 2020 to eliminate the use of Polyvinyl (PVC) and Expanded Polystyrene (EPS) in all packaging by 2025. We ask that as a supplier to Newell
you partner with us in achieving this goal by providing data to report progress annually and support alternative design solutions to replace thesematerials where they exist today
Source100%

Eliminate the use of Polyvinyl Chloride(PVC) and Expanded Polystyrene (EPS) in
all packagingof our direct-sourced paper-based
packaging from certified, verified or
recycled sources
GOAL YEAR

2025

Use at least20%

non-virgin (recycled content) in plastic
packaging for Newell manufactured goods
GOAL YEAR

2025

GOAL YEAR

2025

Product And Packaging Sustainability
Product and Packaging Sustainability Vision
We aspire to share the future of responsible consumption by creating, products that are better for the environment andenable our consumers to live more sustainably.

Our Commitment
We are committed to innovating across our portfolio and dedicated to delivering quality products to customers andconsumers that promote a circular future. We support responsible consumption through our commitment to product andpackaging sustainability.

Supplier Sustainability
Sustainability has transitioned from a buzz word used by a few businesses to the standard means by which companies reduce
their environmental impact, increase employee engagement, and improve profits. Increased sustainability is not contained within
the walls of your facilities but can create positive change upstream and downstream for you. We have outlined a few topics andsteps that you can take to increase your sustainability. We know when you increase your sustainability it benefits everyone so if
you any questions about these or would like help please email us at sustainability@newellco.com.
As a Newell Brands Supplier we reserve the right to request sustainability KPI data from you including packaging bill of materials,
operational and transportation emissions, and inspection measurements that support and drive efficiencies towards product,
packaging, and operational sustainability improvement.

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Corporate Citizenship

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Sustainability Initiative Framework
Below is a framework to help guide you through a successful sustainable program or project. We recommend striving forbalance over trade-offs. Sacrificing one pillar (people, planet, or profit) for another is not sustainable but when we view every
project’s need, implementation, and outcome through the lens of sustainability, a natural balance occurs.

Where too?
Where from?
Who’s going?
What’s the story?

What does success look like for your initiative? (goal, certification, engagement)
What do you know and what do you need to know? (data, baseline, talent)
Who needs to be involved and when? (team, internal, external, partnerships)
How will the story play out? (schedule, budget, urgency)

Measurements, Management, and Success
Reducing the environmental impacts of your operations is a necessary first step in your sustainable journey and there isa natural progression to do that: Measurement & Verification of Utility Consumption, Reduce Consumption and Increase
Efficiencies, and Goals, Reporting, and Adjusting.

Measurement & Verification of Utility Consumption
Creating a system for tracking your utility consumption can be as simple or complex as necessary for your operations. The
utilities we recommend you measure include electricity, fossil fuels (natural gas, heating oils, diesel, etc.), water, and waste(landfill and recyclables). If you have never measured your utilities from a sustainability standpoint, we recommend startingright now and without delay. Measuring and analyzing on a quarterly basis is a good place to start and as you progress you
can transition into conducting a monthly analysis to help you discover utility usage inefficiencies and address them. As
you are measuring these you should also overlay production and/or labor variables. This will give you a quick energy
intensity assessment from which you can see how your consumption relates to production. Once you understand the utility
consumption of your site(s) then you can begin to create programs and projects to make the necessary improvements tolower your utility waste and increase savings.

Reduce Consumption and Increase Efficiencies
After you understand the utilities of your site(s) and how they relate to your production it’s now time to look at removing thewaste while increasing efficiency. We recommend looking for quick and easy wins- lighting (LED conversion, controls), leaks(water and air), electrical (power-off, HVAC maintenance), waste (reduction, reuse, and recycling). A
preventive maintenance, care and service program can help you identify, repair, and keep your production lines and building
running optimally ensuring you are not wasting any energy or water. If you do not have people trained in energy and water
efficiency there are several free resources on-line or you could engage external talent to help you identify and increase
efficiency. We recommend engaging your utility providers to ensure your bill rates match your consumption profile.

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Goals, Reporting, and Adjusting
Utilizing goals and reporting allows you the ability to show improvements and track success. If you have never set sustainability goals
and objectives, we suggest starting with what you can control such as energy, water and waste. Your goals should be long-term
whereas your objectives should be specific and measurable. Please remember not to create these in a silo but to get buy-in and support
from various stakeholders and leadership. Your goals and objectives should not be achievable for where you are in your sustainability
journey. We suggest you review your goals and objectives often and adjust your strategy as needed to ensure your best success.

Responsible Sourcing Guidance for the Supply Chain

Newell believes that sustainable sourcing of products is necessary in order to continue to meet the expectations of our customers
and to help preserve the natural environment. Newell encourages suppliers to join us in working to reduce negative impacts throughadoption of sustainable sourcing practices and increasing transparency and accountability throughout the value chain.

Pulp, Paper, & Timber
Our expectation is our suppliers will make responsible but timely progress in building the necessary systems and tools to
adopt responsible sourcing approaches for pulp, paper, and timber. We are committed to sourcing fiber based packaging
materials from certified, verified, or recycled sources including sourcing from sources certified to globally recognized forest,
fiber, and chain-of-custody certification standards, including Forest Stewardship Council (FSC), Sustainable Forest Initiative(SFI) and Program for Forest Endorsement (PEFC) certification programs.

Palm Oil
We will strive to source palm oil from sources that provide protection for the environment as well asprotection for its workers. Newell Brands is encouraging suppliers to improve their palm oil sourcing practices by sourcing inaccordance to Roundtable on Sustainable Palm Oil (RSPO) standards.

CottonSuppliers to Newell Brands shall not source any Cotton from countries or areas subject to U.S sanctions. Newell Brands is encouraging
all suppliers to evaluate their cotton sourcing methods to ensure they are in compliance with responsible sourcing practices.

Conflict Minerals
Conflict minerals include metals tantalum, tin, tungsten, gold, cobalt, and other derivatives extracted from metallic ore thatare mined and sold in the Democratic Republic of Congo (DRC) and adjoining countries under circumstances that contributeto or support human rights violations. Newell Brands is committed to ensuring that the products it sells do not incorporate“Conflict Minerals.” As required by the U.S. Securities and Exchange Commission (SEC), Newell performs due diligence into
the source of such minerals and discloses the results. Newell Brands requires that suppliers perform due diligence into theirrespective supply chains to determine whether products supplied contain conflict minerals and to what extent those metals
are sourced from conflict-free smelters. Suppliers are required to report their results to Newell Brands to ensure compliancewith legal obligations and policy goals. Suppliers are encouraged to use free standardized reporting resources developed by
the Responsible Minerals Initiative (RMI).

1.Food and Agriculture Organization of the United Nations (FAO).
2.https://www.rspo.org/news-and-events/news/new-partnership-set-to-raise-profile-of-sustainable-palm-oil

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Vendor Code of Conduct

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Newell Brands
Vendor Code of
Conduct
Newell Brands and its subsidiaries and affiliates (collectively,“Newell”) are committed to conducting business activities withthe highest standards of business ethics and in accordancewith all applicable laws and regulations. This Vendor Code of
Conduct applies to all parties providing goods or services to
Newell and their subsidiaries, affiliates and subcontractors(collectively, “Vendors”), whether organized, operating, orexisting under United States law or the law of any other country,
state, political union, municipality, administrative district, orother governmental authority. This Code establishes thestandard of conduct Newell expects from our Vendors in a
number of areas, including human rights, labor requirements,
health and safety, environmental compliance and management
practices. Newell will assess supplier compliance against ourCode. Violations of our Code may result in corrective action,
including termination of the business relationship with Newell.
Newell reserves the right to inspect and/or authorize a third
party to inspect and audit, at any time, whether or not notice isprovided in advance, all Vendors and any location wherea good is designed, manufactured, assembled, handled,
located, or retailed (“Factories”). Vendors shall also permit
Newell’s customers to inspect and audit its Factories to theextent reasonably required or requested by such customer
as a condition of it doing business with Newell. All such
documentation must be accurate, free from any attempt tofalsify or mislead and made available promptly upon request to
any person of Newell conducting an audit.
All vendors are to notify Newell of any material information that
impacts Newell Brands reputation or material issues that might
disrupt supplier or a vendors’ ability to produce products orservices per contractual obligations.

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Vendor Code of Conduct

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Zero Tolerance Issues
There are certain violations that Newell Brands deems as “Zero Tolerance.” These types of violations will not be tolerated andwill likely result in termination of our business relationship. All vendors are expected to have effective management systems
and awareness training in place to manage social compliance within their respective factories and to ensure there are no zerotolerance violations present. Vendors must also ensure there are no banned materials from sanctioned countries or regions
present in products sourced to Newell Brands. Vendor must make their factories aware of zero tolerance issues to ensurecompliance with Vendor Code of Conduct requirements.

Newell Brands Zero Tolerance Violation include:• Child Labor• Forced or Prison Labor• Bribery attempts of any form
• Discrimination• Harassment• Corporal Punishment• Unauthorized Subcontracting• Falsified documents• Denial of Access• Circumvention of audit process• Wastewater discharge into the environment without treatment• Contraband Container Contents• Contraband Contents in Shipping Containers• Cross Border Smuggling

In addition to zero tolerance issues, if we find repeat violations or systemic issues in your factory, we may choose to terminate ourbusiness relationship. Our customers may also prescribe additional violations, in which case you may be subject to termination. It
is the supplier’s responsibility to ensure they are proactively managing risk and understand the program requirements of Newell

Compliance With Laws And Regulations
Comply with all applicable laws in any country in which it conducts business and demonstrate actions in all cases that meet or
exceed those required by applicable law. The term “applicable law(s)” means with respect to any Vendor, any domestic, foreign,federal, state, local or municipal statute, law, ordinance, policy, guidance, rule, administrative interpretation, regulation, order,
writ, injunction, directive, judgment, decree or other requirement of any governmental entity applicable to such Vendor.

Anti-bribery And
Anti-corruption
All Vendors must comply with allanti-bribery and anti-corruption
laws worldwide, and conductbusiness with integrity. Vendors
must never accept or provide
anything of value, either directly
or indirectly, in order to obtain an
improper advantage or to obtain or
retain business (e.g. money, gifts,
meals and transportation). Vendors
must have adequate proceduresin place to prevent bribery in allcommercial dealings undertaken.

Conflicts Of Interest
Vendors must avoid conflicts ofinterest situations. Newell defines a
conflict of interest as being involvedin a relationship or activity that
affects, or has the appearance ofaffecting, your objectivity in making
business decisions in the bestinterest of the company. Vendors
must disclose to Newell any
conflicts of interest situations that
the Vendor is aware of.

Trade And Customs
ComplianceVendors must comply with allapplicable laws and regulations
related to the exportation andimportation of products. In orderto protect the integrity of cargo
being shipped, Vendors muststrive to comply with supply chain
security processes and proceduresconsistent with U.S. Customs Trade
Partnership Against Terrorism(CTPAT) and other relevant
programs such as Authorized
Economic Operator (AEO).

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Employment Practices
Newell Brands expects Vendors to respect its employees and, at a minimum, to be compliant with the requirements below.

Wage And Benefits

Working Hours

Child Labor

Wages paid to employees shallbe at least the minimum wage
under applicable law. Paid annual
leave and holidays shall be paid asrequired by applicable law.

Vendors shall comply withapplicable laws and industry
standards with respect to working
hours and must allow to its
employees at least one day off
during each seven-day period.

Vendors shall comply with allapplicable laws and only employ
individuals who are at, or above, thelegal minimum working age or 15
years of age, whichever is greater,or, the age designated by applicablelaw for completion of compulsory
education. For jobs that require greater
maturity, are hazardous in nature,require night work or pose a safety risk,these employees are to be a minimumof 18 years of age.

Benefits provided by Vendors
and Factories shall include, at aminimum, those mandated byapplicable law.
For each pay period, Vendor
shall provide its employees anunderstandable wage statement.
Wage deductions must not be
excessive and must be itemized
clearly. Wages are to be paid onschedule at least once per monthor such shorter time period as
required by applicable law.

Should overtime work be necessaryor mandatory, employees are to
be advised with reasonable notice.
Vendors shall pay its employees
overtime pay at a rate which ishigher than regular wages and inaccordance with applicable law.
Vendors shall permit its employees
to take all breaks required byapplicable law and, in any event,reasonable breaks, lunch periods
and bathroom breaks.

Vendors shall maintain official
documentation of each employee’s
date of birth. If this documentation
is not available, they must apply alegitimate and reliable method toassess or confirm each employee’s age.
The minimum working age requirement
is applicable to all sub-contracted work
performed, in whole or in part, at homeor in cottage industries.

Forced Or Indentured Labor & Human Trafficking
Vendors shall not use any prison, indentured, bonded or forced labor and shall not source manufacturing inputs like raw
materials and components from suppliers that use forced labor. Vendors agree to provide Newell Brands and/or our auditor
all substantial documentation requested in the audit pertaining to forced labor and subsequent suppliers
Foreign employees must be employed in full compliance with the labor and employment laws of the host country. The
contract terms under which such employees are employed must be in writing, in a language that the employees can read andunderstand, and accepted by the employees prior to their departure from their home countries. Supplier must not withhold
the passports and visas of foreign employees.
Vendors shall maintain and commit to maintaining a work environment that is free from human trafficking. Employment
practices must not include the recruitment, transportation, transfer, harboring or receipt of persons through the use of force
or other forms of coercion, abduction, fraud, deception, abuse of power or by giving or receiving payments or benefits toachieve the consent of a person having control over another person for the purpose of exploitation. Vendors shall not source
any products, components, or materials from suppliers subject to U.S. sanctions or regions with documented evidence offorced labor and human rights violations.

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Vendor Code of Conduct

Discrimination, Harassment &Disciplinary Practices

28

Freedom Of Association

Vendors shall not discriminate against their employees orprospective employees in hiring practices or other terms
or conditions of work on the basis of race, color, national
origin, gender, gender identity, religion, age, disability,
political affiliation, sexual orientation, social or marital
status, maternity, or membership in worker’sorganizations, such as unions, or any other similar factors.

Vendors should respect the rights of their employees tochoose whether to associate with any lawful organization
including labor organizations.

Vendors shall not engage in the use or threat of corporalpunishment, the use or threat of any type of abuse or
harassment, including mental, physical (including sexual)
or verbal, against its employees or the use or threat of any
other form of intimidation. Vendors shall treat all of its
employees with respect and dignity. All major disciplinary
measures taken against employees shall be documented
by Vendors.

Suppliers must provide their employees with a safeand healthy working environment, and where provided,a safe and healthy living environment. Suppliers
shall comply with applicable worker safety laws andregulations which includes:

Environmental
Vendors must comply with all applicable environmental
protection laws. Vendors shall have an implemented
environmental management system (EMS) andenvironmental emergency plan (EEP). It is the Vendor’s
responsibility to ensure there is never any illegal discharge
or dumping of waste or wastewater into local water
bodies, including rivers or streams.

Sub-contracting
Factories agree to perform all final manufacturing andassembly operations to produce products, and that they
will not sub-contract the completion or substantiallyall of the manufacturing or assembly of the products
unless Vendor obtains prior written approval from
Newell. Vendors are responsible for notifying Newell of
any plans for change of manufacturing locations. The
sub-contracting of any work if permitted by Newell, shallnot relieve Vendors from obligations hereunder, including,but not limited to, the obligation to require the companies
providing goods and services to Vendors to comply withthis Vendor Code of Conduct.

Health & Safetyo Building Integrityo Occupational Safetyo Occupational Injury &Illnesso Fire Safetyo Emergency
Preparednesso Machine Safeguardingo Chemical Safetyo Sanitation, Food &Dormitoryo Freedom of Movement

Conflict Minerals
Vendors shall implement procedures to assure thatno products or materials supplied to Newell containconflict minerals (columbite-tantalite (also known ascoltan (tantalum, niobium), cassiterite (tin), wolframite(tungsten), gold, cobalt, or their derivatives) that directly
or indirectly finance armed groups through mining or
mineral trading in the Democratic Republic of Congo oran adjoining country. Upon Newell’s request, Vendors
will fully cooperate in responding to any country of origin
inquiries regarding conflict minerals (including requesting
information from its own suppliers); provide requested
documentation; and/or certify its compliance with thisprovision by providing a sworn declaration of one of its
officers, directors, or managing agents.

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Monitoring Of The Vendor Code Of Conduct
Newell will review this Vendor Code of Conduct on a regular basis and will revise it to incorporate additional parameters whennecessary. This Code is a general statement of Newell’s expectations with respect to its Vendors. The Code should be read in
conjunction with the Vendor’s obligations set forth in the Responsible Sourcing Manual and in any agreements between Newell(or any of its operating divisions) and the Vendor.
It is the responsibility of the Vendor to ensure that it understands and complies with this Vendor Code of Conduct and to inform
Newell (or a member of its management) if and when any situation develops that causes a Vendor to operate in violation of thisVendor Code of Conduct. Vendors are expected to self-monitor their compliance with this Vendor Code of Conduct, therefore,
Newell strongly encourages Vendors to define and implement a policy for social accountability and to adopt or establish amanagement system to ensure that the requirements of this Vendor Code of Conduct can be met in a consistent manner.
In addition to any other rights Newell may have under any agreement it may have entered into with a Vendor, if Newell determinesthat any Vendor fails to comply with or breaches any terms of this Vendor Code of Conduct or has otherwise behaved in a mannerthat is inconsistent with the intent of this Vendor Code of Conduct, Newell reserves the right, in its sole and absolute discretion,
to:
1.
2.

Terminate the business relationship with the Vendor, including the cancellation of any outstanding purchase orders, or
Require corrective actions within an acceptable time period and/or work with the Vendor for an acceptable remedial
program in order for the business relationship to continue or resume.

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Supply Chain Security
Guidelines & Issue Topics

30

Supply Chain
Security Guidelines& Issue Topics
Supply Chain
Security Standards
Newell is a member and partner of the U.S. Customs and Border
Protection in the CTPAT (Customs-Trade Partnership Against
Terrorism) program. In 2020 U.S. Customs released updated and
new CTPAT requirements. These requirements are now referred toas the Minimum Security Criteria (MSC). In conjunction, the World
Customs Organization (WCO) programs, PIP(Canada) and AEO(Europe and Latin America) are aligned with the standards of the
CTPAT program and Newell recognizes Vendors and Factories who
have obtained certification administered by these foreign Customs
administrations.

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Guidelines & Issue Topics

31

Vendors and factories shall meet or exceed the following:1

Adhere to security standards based on the
Minimum Security Criteria to overcome potential
threats posed by terrorism and smuggling
activities in order to safeguard the supply chain.

2Comply with security recommendations resulting
from any third-party audit firm or properly
designated security representative of Newell.

Vendors and factories must develop, implement andfollow standard written security procedures, which
address the following:
Compliance Management

Upper Management Support

It is a best practice for all Vendors and Factories toacquire membership in a World Customs Organization
program such at CTPAT, AEO, PIP etc. Vendors andFactories that belong must ensure that their programs
correspond to the Newell Supply Chain Security
Guidelines

Newell suppliers must have the support of their upper
management. Instilling security as an integral part ofa company’s culture and ensuring that it is a companywide priority is in large part the responsibility of thecompany’s leadership

Risk Assessment
The Newell suppliers must have a risk assessment that
identifies vulnerabilities in their business plan including
geographic location and supply chain risks.

Cyber Security
Written policies and procedures the prevent suppliers’
information systems and data, to include but not limited
to intellectual property, customer information, financial
and trade data and employee records. System musthave protective measures to identify improper use,
tampering and password control.

Business Partners
Written policies and procedures to select business
partners including customers, carriers, othermanufacturers, product suppliers, vendors (parts andraw material suppliers etc.)

Container and Instruments ofInternational Traffic Safety
Written policies and procedures to include container
security, container inspection, container storage, seal
security and storage.

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Guidelines & Issue Topics

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Procedural Security

Agricultural Procedures

Security measures must be in place to ensure theintegrity and security of processes relevant to document
processing, transportation, shipping & receiving, cargodiscrepancies and storage of cargo in the supply chain.

Written policies and procedures to ensure theprevention of visible pest contamination to include
compliance with Wood Packaging Materials regulations.

Physical Security
Cargo handling and storage facilities in domestic andforeign locations must have physical barriers anddeterrents that guard against unauthorized access.
Building structures, fencing, gatehouses, locking
devices, lighting should all be considered.

Personnel Security
Written policies and procedures to screen prospective
employees and to periodically review current employees
to include pre-employment screening, backgroundinvestigation (when available) and termination
procedures.

Physical Access Control
Written policies and procedures to prevent unauthorizedaccess to facilities, maintain control of employees andvisitors and protect company assets.

Security Education,
Training and AwarenessTraining awareness program established andmaintained for all employees and contractors on
policies and procedures related to CTPAT, security,business continuity, risk management and otherspecialized topics.

Newell is a member and partner of the U.S. Customs and Border Protection in the CTPAT (Customs-Trade Partnership Against
Terrorism) program. In conjunction, the World Customs Organization (WCO) programs, PIP (Canada) and AEO (Europe and Latin
America) are aligned with the standards of the CTPAT program which is a threat awareness program that identifies weakness insecurity procedures and introduces needed corrective actions to overcome potential threats posed by terrorist and contraband
smugglers at each point in the foreign based logistical supply chain. Supply Chain Security (SCS) compliance carries valuable
benefits and due to the global nature of Newell business activities, it is perceived as mandatory by many of Newell customers.
The Supply Chain Security Compliance Guidelines below will provide details in meeting the SCS criteria, highlighting the criticalrequirements. This document will serve as an important tool to assist factories in achieving SCS compliance.
TOPIC

1

Compliance Management
It is a best practice for all Vendors and Factories to acquire membership in a WCO program such as CTPAT, AEO, PIP
when applicable. Vendors and Factories that belong must ensure that their program corresponds to the Newell Supply
Chain Security Guidelines including:

•
•
•
•

Identify person(s) of responsibility for the program and liaison with governmental agency as applicable
Establish a comprehensive manual based on the program criteria to include annual review of the policy and procedures,and update as needed
Training program for all employees
Identify international supply chain process and conduct a risk and vulnerability assessment

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Supply Chain Security
Guidelines & Issue Topics

33

Upper Management Support
In promoting a culture of security, CTPAT Partners should demonstrate their commitment to supply chain security andthe CTPAT Program through a statement of support. The statement should be signed by a senior company official anddisplayed in appropriate company locations. Support should include the following:

•
•
•
•
•
TOPIC

3

Incorporate representatives from all relevant departments into a cross function team
Point of Contact who is knowledgeable in CTPAT requirements
Accountability (ADHERE TO written policy and procedure and identify who is accountable)
CTPAT manual that is updated annually to meet updated criteria
Reporting of regular updates and issues

Risk Assessment
Factories must conduct and document a risk assessment to determine the risk in their supply chains. Mapping should
include the following:

•
•
•
•
TOPIC

4

Mapping cargo flow including when cargo is at “rest”
Business partners
Manufacturing, distribution locations
Modes of transportation

•
•
•
•

Threat assessment
Vulnerability assessment
Audit assessment
Action Plans

Business Partners
The facility must have written, verifiable processes and procedures used in the selection of business partners including
material suppliers, manufacturers, and logistics service providers.
The facility must incorporate and require minimum supply chain security requirement language in contracts with abusiness partners.
Contracted business partners are required to conduct and provide an annual security risk assessment of theiroperation. These business partners include any contract services, such as security, transportation provider, freightconsolidation or manufacturing labor.

TOPIC

5

Cyber Security
In today’s digital world, cybersecurity is the key to safeguarding a company’s most precious assets – intellectual
property, customer information, financial and trade data, and employee records, among others. With increased
connectivity to the internet comes the risk of a breach of a company’s information systems. This threat pertains
to businesses of all types and sizes. Measures to secure a company’s information technology (IT) and data are ofparamount importance, and the listed criteria provide a foundation for an overall cybersecurity program. CTPAT criteria
is below:
Accountability – comprehensive written cybersecurity policies and/or procedures to protect information technology(IT) systems. The written IT policy, at a minimum, must cover all of the individual Cybersecurity criteria comprehensive
written cybersecurity policies and/or procedures to protect information technology (IT) systems. The written IT policy, ata minimum, must cover all of the individual Cybersecurity criteria

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Cyber Security (Continue)

5
1.
2.
3.
4.
5.

TOPIC

6

Supply Chain Security
Guidelines & Issue Topics

Hardware
Software
Email and internet
Intrusion detection
Password automation

6.
7.
8.
9.

Regular reviews of IT infrastructure to identify vulnerabilities
If vulnerabilities are found, instate a corrective action plan.
User restriction based on job restriction
Data will be backed up once a week

Container & Instruments of International
Traffic Safety
Written policies and procedures to include container security, container inspection, container storage, seal security andstorage.

Container Security and inspection••

Policies and procedures must be in place to verify the physical integrity of the container structure prior to stuffing toinclude the reliability of the locking mechanism of the doors.
Based on CTPAT and WCO standards it is recommended to follow the “seven-point” inspection process for all containers.
• Front Wall
• Left Side

• Right Side
• Floor• Ceiling / Roof
• Inside / Outside doors• Outside /Undercarriage

Container Storage
Containers must be stored in a secure area to prevent unauthorized access and/or tampering. Container doors should be secured
by seals or positioned not to allow container doors to be opened (back to back). Policy and Procedures must be in place forreporting, preventing unauthorized access to the interior of the container and/or storage areas.

Seal Security and Storage
High security seals must be affixed to all loaded containers bound for the U.S. All seals must meet or exceed the current PAS ISO
17712 standards for high security seals.
Policies and Procedures to ensure seal security to include:•••

Seal control and accountability
Designated person(s) of responsibility
Proper method to affix to the container••

Recognizing and reporting of compromised seals or container
to proper authority
Proper disposal of used seals.

Conveyance Security
Driver information should be recorded and retained for all departing shipments and written procedures in place instructing thedrivers to take designated routes between the origin and the port. Transit routes from the factory to the port or next destination
location should be randomly changed to minimize predictability. When applicable tracking technology should be used by thetransportation company

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Supply Chain Security
Guidelines & Issue Topics

35

Procedural Security
Security measures must be in place to ensure the integrity and security of processes relevant to document processing,transportation, shipping & receiving, cargo discrepancies and storage of cargo in the supply chain.

•

Documentation Process:• Legible• Complete• Accurate• Protected against the exchange, loss or introduction of erroneous information• Documentation control must include safeguarding computer access and information.

•

Manifest Procedures to ensure the integrity of cargo received from abroad must be in place to ensure
information received from business partners is reported accurately and timely.

•

Shipping and Receiving:• Cargo should be reconciled against the manifest• Cargo should have accurate description• Weights, labels, marks and piece count recorded
and verified•• Departing cargo should be verified against thepurchase order• Drivers delivering or receiving cargo must be positively
identified (photo ID) prior to cargo received or shipped

Cargo Discrepancies, all shortages and overages and other anomalies must be resolved and/or
investigated appropriately internally and externally. Customs and/or other appropriate law enforcement
agencies must be notified if illegal or suspicious activities are detected. As appropriate based on current
law or governmental structure.

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Agricultural Procedures
Agriculture is the largest industry and employment sector in the U.S., an industry threatened by the introduction offoreign animal and plant contaminants such as soil, manure, seeds, and plant and animal material which may harborinvasive and destructive pests and diseases. Ensuring compliance with CTPAT’s agricultural requirements will help
protect a key industry in the U.S. and the overall global food supply.

Pest Contamination - Wood Packaging Materials (WPM)
Factories must have written procedures designed to prevent visible pest contamination to include compliance with
Wood Packaging Materials (WPM) regulations. Visible pest prevention measures must be adhered to throughout the
supply chain.
Newell Rubbermaid suppliers, vendors and transportation providers are required to inspect containers prior to loadingfor pest contamination. This is part of the Newell Brands 7 -point inspection process.

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TOPIC

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Supply Chain Security
Guidelines & Issue Topics

36

Physical Security
Cargo handling and storage facilities in domestic and foreign locations must have physical barriers and deterrents that
guard against unauthorized access. Building structures, fencing, gatehouses, locking devices, lighting should all beconsidered.
The following CTPAT and / or WCO criteria should be implemented throughout the supply chain as applicable:

Fencing

Gates and Gate Houses

Parking

Perimeter fencing should
enclose the areas around cargohandling and storage facilities.
Interior fencing within a cargohandling structure should be
used to segregate domestic frominternational, high-value, andhazardous cargo. All fencing must
be regularly inspected for integrity
and damage.

Gates through which vehicles and/or personnel enter or exit must be
manned and/or monitored. The
number of gates should be kept tothe minimum necessary for proper
access and safety.

Private passenger vehicles should
be prohibited from parking in or
adjacent to cargo handling andstorage areas.

Building Structure

Locking Devices and
Key Controls

Buildings must be constructed ofmaterials that resist unlawful entry.
The integrity of structures must be
maintained by periodic inspection
and repair.

All external and internal windows,
gates and fences must be secured
with locking devices. Management
or security personnel must control
the issuance of all locks and keys.

Lighting
Adequate lighting must be provided
inside and outside the facility
including the following areas:
entrances and exits, cargo handlingand storage areas, fence lines andparking areas.

Alarms Systems and Video Surveillance Cameras
Alarm systems and video surveillance cameras should be utilized to monitor premises and prevent unauthorized access tocargo handling and storage areas.

Alarms and video servalance systems must have random periodic reviews of footage

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Physical Access Controls
Written policies and procedures to prevent unauthorized access to facilities, maintain control of employees and visitors
and protect company assets.
Access controls must include the positive identification of all employees, visitors, and vendors at all points of entry,
deliveries (mail).
Access controls include the following:

Employees
Policies and Procedures must be implemented to protect against unauthorized personnel from entering the facility. Ingressand egress locations should be kept to a bare minimum based on size and population.
Implementation of an employee identification system must be place for positive identification and control purposes. Accessto secure areas should be granted only to those employees who need access based on the performance of their duties.
The overall identification badge and access process must include the following:o Develop application and tracking process
o Standard ID badge with employee name,company name, photographo Control of issuance and removalo Limit access to secure areas needed toperform duties
o Designated person(s) to manage the program

Visitors and Vendors

Temporary Employees

All visitors and vendors must present photo identification
for proper identification upon arrival. Proper
documentation process must be in place (electronically
preferred) to record name, company, person being
visited, date and time. Visitors will be provided atemporary badge to be worn at all times while on theproperty. All visitors/vendors should be escorted andare required to display the issued visitor/vendor badge.
Upon completion of the visit, the visitor will returnthe badge. Visitor logs are maintained and retained
according to recordkeeping retention procedures.

Will be issued appropriate identification, which will beworn on their person at all times while on the property.
Identification will specify the areas, or designated areas,
to which the holder has been granted access. Badges
for vendors and temporary employees will only be valid
for the duration of their assignment. A separate log will
be maintained to keep track of vendor and temporary
employee badges.

Deliveries (Mail)
All mail should be delivered to a designated mail room. All packages should be routinely inspected with a process in place toaddress suspicious packages. Delivery personnel must present proper ID and/or photo identification upon arrival, informationmust be documented and retained
Delivery Drivers and Commercial Vehicles must stop at the gatehouse or designated location at facilities maintaining
gatehouses or checkpoints. All drivers must present photo identification. Commercial vehicle drivers are restricted todesignated waiting areas while trucks/trailers are loaded and unloaded.

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Challenging and Removing Unauthorized Person(s)Policy and Procedure must be in place to identify, challenge and address unauthorized/unidentified persons. Employees mustbe trained on the process to include reporting and escalation process

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Personnel Security
Written policies and procedures to screen prospective employees and to periodically review current employees toinclude pre-employment screening, background investigation (when available) and termination procedures.

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Pre-Employment Verification Application information, such as employment history and references, must be verified
prior to employment
Background Investigations Background Checks/Investigations: It must be recognized that under Newell CTPAT
and/or WCO standards business units should comply with foreign, federal, state and local regulations. Periodic
checks and reinvestigations should be performed based on cause and/or the sensitivity of the employee’s position.
Personnel termination procedures must be in place to ensure identification badges are returned, facility, and systems
access removed for terminated employees and/or contractors to include documentation.

Education, Training, and Awareness
Policy and Procedures must be implemented to ensure security and awareness training programs are established andmaintained to recognize to include awareness of the threat of terrorism at each point in the supply chain. Employees
and/or contractors must be made aware of procedures Newell has in place to react and how to report. The program
should address but not limited to the following:
The Policy and Procedures must have periodic “refresher training” specific to signs of hidden compartments, concealed
contraband in naturally occurring compartments and signs of pest contamination.

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Threat posed by terrorism
Maintaining cargo integrity
Recognizing internal conspiracies
Protecting access control

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Specialized training for shipping and receiving personnel
Handling unauthorized person(s)Loss prevention
Bomb threats

Additional training should be provided to employees and/or contractors assigned to shipping and receiving. The
training should be specific to the following:•••

Maintaining cargo integrity
Recognizing internal conspiracies
Protecting access controls

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Heightened global enforcement of anti-forced laborcompliance is leading to specific criteria for supply
chain transparency
The reasons for this increased visibility are clear: Companies are under pressure from governments, consumers, NGOs,
and other stakeholders to divulge more information about their supply chains. The reputational cost of failing to meetthese demands can be high.
At Newell Brands Inc., we are committed to meeting the expectations of the governments where we do business andour customers. We are adhering to a single comprehensive program that will meet the most rigorous of these laws,
regulations and consumer expectations.
In order to comply with the concept of “rebuttable presumption”, Newell Brands requires all suppliers to provide supply
chain details that support our due diligence initiatives.

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Suppliers must be engaged in the Forced Labor risk assessment
Suppliers will provide details on upstream raw materials and components including vendors names, locations/addresses and contacts.
Affidavits from each company or entity involved in the production process and an acknowledgement that a physicalaudit of their facilities will be welcomed.
Suppliers agree to remediate any findings of Forced Labor or gaps in due diligence.
Supplier agrees to provide Evidence Pertaining to Merchandise or Any Component Thereofo Purchase orderso Invoice for all suppliers and sub-supplierso Packing listo Bill of materials
o Certificates of origino Payment records
o Seller’s inventory records, including dock/warehouse receiptso Shipping records, including manifests, bills of lading (e.g., airway/vessel/trucking)o Buyer’s inventory records, including dock/warehouse receiptso Invoices and receipts for all suppliers and sub-supplierso Import/export records

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