California Transparency Act

Newell Brands is a global consumer products organization with a broad portfolio of widely recognized brands, including Sharpie, Graco, Oster, Yankee Candle, Rubbermaid, and Coleman. Headquartered in the United States, the company employs close to 24,000 people worldwide and conducts business through three primary segments: Learning and Development, Home and Commercial, and Outdoor and Recreation. Its products are marketed in more than 150 countries, with operational facilities in over 40 of them. Manufacturing takes place both domestically and internationally, supported by a combination of company-operated sites and third-party partners that assist in production and material sourcing. Approximately 14,000 employees are directly involved in manufacturing and supply chain functions, while additional workers contribute through independently operated facilities across the globe.

A central priority for the organization is maintaining ethical standards throughout its operations and supply chain. The company has taken a firm stance against modern slavery and is committed to ensuring that forced labor, human trafficking, and child labor have no place within its business activities. Transparency and accountability are emphasized across its global supplier network, which includes more than 18,000 suppliers located in over 90 countries. These suppliers range from large multinational enterprises to smaller regional businesses. Procurement strategies are structured to benefit from supplier capabilities and efficiencies while maintaining oversight through a comprehensive Responsible Sourcing Program. This framework supports ethical procurement practices and aligns with international human rights principles.

Internal governance documents reinforce these commitments. The company’s Code of Conduct outlines expectations for employees, providing guidance on ethical decision-making and compliance with labor laws. It strictly prohibits forced labor, child labor, and any form of physical abuse. The Code also underscores the importance of lawful wages, respect for freedom of association, collective bargaining rights, and equal opportunity in employment practices. Employees receive this guidance at the start of their employment and are required to complete training programs to reinforce understanding and adherence.

Suppliers are subject to parallel expectations under the Vendor Code of Conduct. This policy requires business partners to maintain safe workplaces, treat workers with dignity and respect, comply with all applicable labor regulations, and operate free from forced or trafficked labor. Suppliers must confirm their compliance annually. When significant violations are identified, corrective actions are mandated, and severe breaches can result in termination of the partnership. Senior leadership reviews critical findings in collaboration with procurement, legal, ethics, and compliance teams to determine appropriate responses and ensure accountability.

Due diligence procedures apply to both prospective and established suppliers. Evaluations consider operational capability, financial reliability, and adherence to social compliance standards. Audits may be conducted with advance notice or without prior warning and are performed either by internal specialists or qualified third-party assessors. Continuous improvement plans guide remediation efforts where deficiencies are found. Participation in collaborative initiatives such as SEDEX and SCAN strengthens oversight mechanisms and enables targeted attention to higher-risk regions or product categories.

In 2024, the company enhanced its approach to identifying and mitigating forced labor risks. Efforts included deeper supply chain mapping, expanded third-party risk assessments, and increased traceability for materials considered higher risk, such as cotton, latex, and rubber. Twelve additional suppliers underwent traceability evaluations during the year, reflecting a broader commitment to understanding sourcing practices at more detailed levels.

Ongoing engagement remains central to the Responsible Sourcing Program. During 2024, initiatives included hosting a Responsible Sourcing Supplier Summit, delivering updated training programs, revising the Vendor Code of Conduct, and completing numerous audits accompanied by structured corrective action plans. These measures aim to strengthen oversight, elevate awareness of human rights responsibilities, and promote fair working conditions throughout the supply chain.

This statement outlines actions taken during the 2024 calendar year to prevent modern slavery and protect human rights. It was prepared with input from multiple internal departments, including Ethics and Compliance, Global Supply Chain, Human Resources, Legal, Procurement, and Responsible Sourcing, and received approval from the Board of Directors on May 8, 2025. The document reflects the organization’s ongoing dedication to ethical conduct, operational transparency, and continuous improvement across its worldwide operations.