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Anti-Human Trafficking Statement

INTRODUCTION

Allegion believes businesses have a central role to play in combating modern slavery and human trafficking. In staying true to one of its core values “DO THE RIGHT THING”, Allegion has zero tolerance for all forms of modern slavery, human trafficking and child exploitation throughout its global organization, operations and supply chains.

Allegion is committed to fair labor practices and the protection of workers against labor rights violations.  Allegion seeks to maintain and improve its processes while implementing systems and controls for compliance with all applicable laws across the globe.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and the California Supply Chains Act of 2010 (SB 657) and constitutes Allegion’s slavery and human trafficking statement for the fiscal year 2015/16. Allegion will review and publish this statement annually.

ORGANIZATIONAL STRUCTURE  

Allegion is a $2 billion global company of experts who help customers overcome new and complex security challenges by providing reliable, high quality residential and commercial mechanical and electronic security products and solutions for homes and businesses.

Our global footprint spans more than 30 countries with 40+ manufacturing and distribution sites.  We employ over 9000+ associates and supply over 25+ product brands to ~130 countries across the globe. 

Our global headquarters is located in Dublin, Ireland with 3 regional headquarters located in the America’s (Carmel, Indiana), Asia Pacific (Shanghai, China) and EMEIA (Faenza, Italy).  To learn more about our business, please visit:  http://www.allegion.com

SUPPLY CHAIN

Our domestic and international supply chains include the sourcing of both raw materials and components principally related to the manufacture of mechanical and electrical security products as well as Original Equipment Manufacturer (OEM) supplied security related product.

ORGANIZATIONAL POLICIES  

Our commitment to ethical behavior and compliance can be found throughout our policies and our Allegion Code of Conduct.  We believe that the fundamental values set forth in these policies should serve as our global minimum business standards.

To ensure our policies and guidelines reflect industry best practices, Allegion is an active member of the following organizations: CFSI (Conflict free Sourcing Initiative), and CEB/Gartner.  We also actively participate in C-TPAT (Customs – Trade Partnership against Terrorism) and the AEO (Authorized Economic Operator) programs to help facilitate best supply chain security standards.  

As defined in our Allegion Code of Conduct for Business Partners, Allegion expects that its business partners, including its suppliers, vendors, consultants, and contract labor to adopt and enforce standards similar to those defined in these policies.

 

Allegion Code of Conduct and Corporate Governance Documents:

http://investor.allegion.com/corporate-governance/governance-documents

Allegion Code of Conduct for Business Partners:

http://www.allegion.com/suppliers

Corporate Social Responsibility:

http://investor.allegion.com/company-profile/sustainability

Allegion Conflict Minerals Policy:

http://www.allegion.com/corp/en/investor-relations/conflict-minerals.html

 

VERIFICATION AND DUE DILLIGENCE

Verification and Risk Assessment:

In 2016, Allegion performed an initial risk overview of its supply chain using the Global Slavery Index and the US Department of State Trafficking in Persons Report to identify any notable high risk suppliers based on their supplier location and Allegion’s knowledge of their operation and practices. 

To further strengthen the program and test the effectiveness of its supply chain risk screening methodology, Allegion also contracted with a third-party provider to perform a pilot risk level assessment of its direct material suppliers. 

The assessment involved a subset of Allegion suppliers that was representative of its global direct material supply chain. This assessment took into consideration well-known risk factors of slavery and human trafficking, including the geographical location, industry and workforce characteristics of each unit, and engaged staff across different departments.

The assessment was performed using an industry standard open-source Human Trafficking Risk Template (HTRT) to survey Allegion’s supply chain for risk indicators of slavery and human trafficking. The template collected data in a standardized manner, much like the Conflict Minerals Reporting Template (CMRT). 

This process allowed Allegion to also efficiently and directly engage with its suppliers and foster a constructive dialogue to promote supplier awareness of its expectations regarding the protection of workers from slavery and human trafficking.  For additional information about the HTRT, including the risk factors it addresses, please visit www.htrt.org.

In 2017, Allegion will perform a full risk assessment of all of its global direct material and logistics suppliers, and will use these findings to inform and prioritize our risk mitigation action.

Internal Accountability:

Allegion annually conducts Code of Conduct awareness training. A violation of the Code of Conduct may result in discipline, up to and including termination and/or reporting of the misconduct to the relevant government authorities. 

Supplier accountability

Allegion is committed to working with its suppliers to both mitigate and address any identified risk. Allegion will do so through a range of different approaches, including:

  • Annual internal assessment of supply chain risk based on international indices, supplier performance, and other indicators of supplier-specific risks.
  • Annual supplier AHT self-assessment.
  • Perform internal audit on supplier sites showing high risk with the HTRT risk or supplier sites demonstrating known risk factors for human trafficking
  • New supplier screening, on-site-assessments (OSA) and qualification
  • Long term supplier relationships and approved supplier lists (ASL)
  • Supplier scorecards and supplier business reviews.
  • Contract language

Violation of the Business Partner Code of Conduct may result in termination of the supplier relationship and/or reporting of the misconduct to the relevant authorities.

Grievance Mechanism

Allegion has also established a Helpline to ensure lawful and ethical behavior and to maintain compliance with Allegion’s Code of Conduct and Ethical Sourcing Policies & Guidelines.

This confidential, non-retaliatory resource is available for any internal and external stakeholder to inform Allegion of concerns or report findings of non-compliance by sending an e-mail or by using our third-party hotline.

Reports can be made anonymously and will be kept confidential to the extent practicable and allowed by law.

Phone:                 United States and Canada:  (855) 807-3267

CAPACITY BUILDING/TRAINING

Allegion’s zero tolerance approach to modern slavery will be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Starting in 2017, strategic and high risk, suppliers and Allegion employees, who have direct responsibility for supply chain management and recruitment, will receive annual training on slavery and human trafficking, as well as related regulations, through our third-party provider’s on line training.  With this mandatory, annual training platform, stakeholders will build their capacity to identify and respond to slavery and human trafficking risks within Allegion’s global operations and supply chain.

In addition, our supply chain risk management team will have access to continuing education conferences and webinars to help them better understand identification of and risk mitigation of these violations

CLOSING/ RESPONSIBILITY FOR THE POLICY

This statement was approved by the Board of Allegion, on <date>.

 

By:         /s/ David D. Petratis                                                     

David D. Petratis

Chairman, President and Chief Executive Officer