California Supply Chain Transparency Policy
Church & Dwight's products have been a standard of quality and environmental responsibility since 1846. We are a global consumer products group. Church & Dwight Co., Inc., is the parent company of a number of companies spread across the globe, including Church & Dwight UK Ltd. Together with Church & Dwight Co., Inc., these companies make up the Church & Dwight group or "Church & Dwight". More information about the company, its structure and its operations are available here.
We are committed to conducting our global operations in a responsible manner and expect the same commitment from our suppliers. Combatting modern slavery and human trafficking in our business and our supply chain is therefore important. The California Transparency in Supply Chains Act of 2010 and the UK's Modern Slavery Act of 2015 require manufacturers and retailers doing business in California and/or the UK to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. Church & Dwight's efforts include the following:
- Our Guiding Principles. All of our suppliers are expected to abide by the Church & Dwight Co., Inc. Global Operations Guiding Principles ("Guiding Principles") which set out minimum standards for working conditions that are safe and afford workers respect and dignity. The Guiding Principles were developed based on the principles of internationally recognized human rights and labor conditions and reflect our commitment to sustainable operations. They are substantially aligned with the United Nations Declaration on Human Rights, the International Labor Organization's 1998 Declaration on Fundamental Principles and Rights at Work and the Labor Principles of the United Nations Global Compact. They are also substantially aligned with the Ethical Trading Initiative Base Code. The Employment Standards within the Guiding Principles provide that "employees must be employed of their own free will," suppliers are not permitted to utilize "forced labor in any form," may not utilize corporal punishment as a form of discipline, and must pay employees wages required by law. The Guiding Principles also prohibit vendors from engaging in or supporting "trafficking of individuals" and require vendors to have "appropriate systems in place to ensure compliance with slavery and human trafficking laws."
- Our Supplier Contracts. Our supplier contracts require suppliers to conduct their operations in accordance with all applicable laws and the Guiding Principles. In addition, consistent with the Guiding Principles, our supplier contracts include a forced labor warranty which requires suppliers to warrant that they do not employ "prison labor, indentured labor, bonded labor or use corporal or other forms of mental and physical coercion as a form of discipline" and that they "will not conduct business with vendors employingâ€¦prison labor, indentured labor, bonded labor or who use corporal punishment or other forms of mental and physical coercion as a form of discipline."
- Supplier Qualification. While we currently do not have a formal verification program, in 2017 we are launching a program to assess supplier risk and pre-qualify new suppliers against the standards set forth in the Guiding Principles, including the prohibition on forced labor and trafficking. Church & Dwight is engaging a third party auditor to perform the verification process, which will require new suppliers and higher potential risk existing suppliers to complete questionnaires in order to monitor and assess risk in our supply chains.
- Our Audit Program. While we currently do not have a formal social audit program, we have conducted social audits of some suppliers through independent audit firms. In 2017 we are launching a comprehensive audit program using independent audit firms which will be used to hold our suppliers accountable to the standards set forth in the Guiding Principles. We will conduct comprehensive social audits of certain of our higher potential risk suppliers. The audit program is being implemented as a semi-announced audit program pursuant to which the factory to be audited is given an agreed upon window of three weeks during which the auditors may arrive at any time unannounced.
- Our Audit Standards. The structure of an audit will generally follow Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance. In order to clearly identify high-risk suppliers within our supply chain where there is an increased risk of modern slavery, we will, among other factors, utilize UL's Global Risk Index, which includes World Bank Worldwide Governance Indicators; the US State Department Human Trafficking Report; and the US Department of Labor Forced Labor List.
- Violations Response. Any supplier found to be in violation of the Guiding Principles will be subject to corrective action, which may include termination of business.
- Training. Church & Dwight requires all of its employees and management to abide by our Code of Conduct. Our Code of Conduct requires that we maintain the highest ethical standards and never take unfair advantage of anyone. It was designed to encourage a culture of honesty, accountability and mutual respect; to provide guidance to help personnel recognize and deal with ethical issues; and to provide a reporting mechanism for company personnel to report unethical conduct. While existing and new employees (including but not limited to relevant management-level personnel) directly involved in procurement, supply chain and other relevant functions have not yet received specific training regarding modern slavery, human trafficking, and mitigating risks within the supply chain of products, many of them have been involved in designing our Responsible Sourcing Program that includes all of the elements set forth in this Policy and they are familiar with the details of our Responsible Sourcing Program. Moreover, in 2017 we will develop a training program for applicable employees and management regarding the Global Operations Guiding Principles, including its prohibition on slavery and human trafficking within our supply chains. That training program will supplement training that is provided to all employees with respect to our Code of Conduct that applies to all employees and directors and that require compliance with applicable laws, including those prohibiting slavery and human trafficking.
- Addressing Violations. While Church & Dwight does not have a separate internal accountability policy for human trafficking and slavery, any violation of applicable laws, our Code of Conduct, Company policies or the Guiding Principles by a Church & Dwight employee, including violations of laws and policies regarding slavery and human trafficking, may result in disciplinary action up to and including termination of employment, in accordance with applicable law.
- Reporting Concerns. To report a concern, talk to your Church & Dwight representative. If you prefer to remain anonymous, you may go to www.churchdwight.ethicspoint.com or call the Church & Dwight Hotline at one of the toll free telephone numbers available here; both the web site and telephone numbers are administered by an independent third party.
- Oversight. In 2016, Church & Dwight established the Corporate Issues Council. The Council is comprised of Church & Dwight senior executives and other leaders representing functional areas across the enterprise. The Council takes the lead in defining and implementing our sustainability strategies concerning human rights and labor conditions in our operations and supply chain, among other things. The Council, which meets quarterly, monitors adherence to our Global Principles. Concerns can also be reported as set forth above. Our Board of Directors, through its Governance & Nominating Committee oversees our sustainability program.
Church & Dwight will continue to review its policies and procedures to make sure we have appropriate safeguards in place to protect persons employed in bringing out products to our consumers.
This statement is made pursuant to The California Transparency in Supply Chain Act of 2010 (SB 657) and section 54(1) of the UK's Modern Slavery Act of 2015 and constitutes the Church & Dwight group's slavery and human trafficking statement for the financial year ending 2016.
Approved by Church & Dwight's Board of Directors on May 3, 2017
Matthew T. Farrell