Anti-Slavery and Human Trafficking Statement

INTRODUCTION

Allegion believes businesses have a central role to play in respect for human rights, combating modern slavery and human trafficking. In staying true to one of our core values “Do The Right Thing”, we prohibit and have zero tolerance for all forms of modern slavery, human trafficking and child exploitation throughout our global organization, operations and supply chains.

We are strongly committed to fair labor practices and the protection of workers against labor rights violations.  Allegion will continue to maintain and improve processes while implementing systems and controls to ensure that our business and supply chains across the globe are free of such practices.

This statement constitutes our slavery and human trafficking statement for the fiscal year ended 31 December 2019 and is made pursuant to Section 54 of the UK Modern Slavery Act 2015, Part 2 of the Australian Modern Slavery Act of 2018, and the California Supply Chains Act of 2010 (SB 657).  These Acts require Allegion to disclose our efforts to combat modern slavery and human trafficking and detail the steps Allegion has taken to ensure such practices are not taking place in our business and supply chains. We will continue to review and publish this statement annually for Allegion plc, Allegion (UK) Limited, Allegion Investments (UK) Limited, and Allegion (Australia) Pty Ltd.

ORGANIZATIONAL STRUCTURE 

Allegion (NYSE: ALLE) is a global pioneer in seamless access, with leading brands like CISA®, Interflex®, LCN®, Schlage®, SimonsVoss® and Von Duprin®. Focusing on security around the door and adjacent areas, Allegion secures people and assets with a range of solutions for homes, businesses, schools and institutions.

Allegion had $2.9 billion of revenue in 2019 and has more than 30 brands sold in almost 130 countries across the globe with the knowledge and experience of nearly 11,000 dedicated employees.

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

SUPPLY CHAIN

Allegion is in the security industry and while mechanical hardware is the foundation of our business, Allegion also provides digital, mobile and interconnected electronic solutions to global markets. Specializing in security around the door, Allegion manufactures electronic and mechanical locks, door closers, exit devices, steel doors and frames among other products, and creates practical safety solutions including biometrics, wireless connectivity and cloud technology.

With more than 25 manufacturing sites around the world and multiple distribution centers spread across five different continents, our Global Supply Management team is responsible for purchasing products and services from external partners used to manufacture products, deliver those products to our customers and run the day-to-day operations of our business.

Allegion’s supply chain includes suppliers in Americas, Europe, Middle East and Asia Pacific regions. Activities involve the transformation of zinc, brass, steel and other materials into parts used to build Allegion products and include various manufacturing processes to create supplementary components and key electronic mechanisms.

Allegion’s supply chain structure supports the complexities of global supply and manages associated risks, including compliance with regulatory directives and monitoring supplier’s performance and financial stability.  The supply chain structure includes a strategic sourcing team of commodity managers responsible for managing purchased components. Commodity managers create and execute commodity playbooks, select suppliers, manage supplier relationships and performance, and lead commercial activities (agreements, pricing, payment terms, etc.). 

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 and our Code of Conduct should serve as our global minimum business standards. For example, Allegion has policies and procedures in place to ensure the procurement of goods and services is conducted in a competitive, fair, and transparent manner that delivers the best combination of quality, value, and risk from our suppliers in support of Allegion’s global enterprise goals.

To ensure our policies and guidelines reflect industry best practices, Allegion is a member of The Society of Corporate Compliance and Ethics and Gartner, which are compliance organizations providing guidance for the continued development of compliance and ethics related programs.  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.  Further, Allegion is a voting member of the Social Responsibility Alliance and participates in the Slavery & Trafficking Risk Template (STRT) Development Committee, the organization that maintains the standardized STRT which is issued globally by companies in their supply chain transparency programs.

As defined in our Allegion Code of Conduct for Business Partners, Allegion also expects that our business partners, including our suppliers, vendors, consultants, and contractors adopt and enforce standards similar to those defined in our policies which are included as links below.

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 DILIGENCE

  • Verification and Risk Assessment:

Allegion has partnered with a third-party provider, Assent Compliance, to assist with the identification and risk mitigation of any modern slavery and human trafficking practices throughout our global supply chain.  Allegion annually uses the Global Slavery Index (GSI) and the U.S. Department of State Trafficking In Persons Report (TIP) to identify geographical high-risk areas where direct spend suppliers are located.  Our suppliers are surveyed and assessed for risk of slavery and human trafficking using an industry standard open-source template, the Slavery & Trafficking Risk Template (STRT) available at www.sraglobal.org.  In 2019 - 2020, we campaigned on version 1.3 of the STRT. 

Our approach enables us to assess the strength of the supplier’s risk mitigation activities in relation to their risk exposure based on geographical location, industry, use of labor brokers and workforce characteristics, and it serves as the initial assessment of potential risk within our supply chain.  Engagement of the suppliers in completing the risk assessment process and providing supporting documentation enables us to raise supplier awareness, foster constructive dialogue and engage their support in helping us maintain our commitment to combat and mitigate slavery and trafficking risk in the supply chain.  In 2019, the supplier campaign was expanded to include 95% of direct spend suppliers (as reflected in Allegion’s spend management system), 25% of logistics spend suppliers, and 10% of indirect spend suppliers. Extending the campaign to service providers allowed Allegion to further the understanding of risks within our supply chain. In 2020, we plan to focus on targeted improvement, specifically assisting our supply base with training and policy development, as appropriate.

  •  Internal Accountability:

Allegion’s Code of Conduct reinforces our commitment to following the law in all places where we do business and it applies to all of our officers, employees and directors. Our Code guides our business relationships with customers and suppliers and it also emphasizes what’s expected of Allegion by shareholders, government regulators and the communities we serve.

All Allegion employees must get to know our Code.  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 our suppliers to both mitigate and address any identified risk.  As part of our terms and conditions of purchase, we require all suppliers to comply with applicable local law and regulations.  Additionally, our terms and conditions state that our suppliers will not utilize child, slave, prisoner, or any other form of forced or involuntary labor, or engage in abusive employment or corrupt business practices.

To reinforce supplier’s engagement with global initiatives to eradicate human trafficking and modern day slavery, during our 2019 Allegion supplier conference, the supply chain compliance team provided an overview of the global magnitude of human rights abuses.  Suppliers were encouraged to continue the message of social responsibility and cascade the awareness further into their operations.

Our terms and conditions also require all suppliers to follow our Business Partner Code of Conduct, the violation of which may result in termination of the supplier relationship and/or reporting of the misconduct to the relevant authorities.

  • Grievance Mechanism

Allegion has an established Helpline to help ensure concerns regarding lawful and ethical behavior are reported 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.

Email:              EthicsandCompliance@allegion.com

Phone:            United States and Canada:  855 807 3267

                         United Kingdom: 0 808 189 1053

                         Australia: 0011 800 1777 9999

CAPACITY BUILDING/TRAINING

Training on slavery and human trafficking and related regulations is provided through our third-party provider Assent University.  This training platform helps our employees to build their capacity to identify and respond to slavery and human trafficking risks. Since 2018, 80% of Allegion employees who have direct responsibility for global supply management have completed this training online. The completion percentage is impacted by staff turnover, retirements and internal transfers.

In addition to the training, continuing education conferences and webinars for our supply chain risk management team are made available through Assent Compliance to help us better understand identification of, and risk mitigation of, these violations.

CLOSING/ RESPONSIBILITY

The Allegion Board of Directors has overall responsibility for ensuring this statement complies with our legal and ethical obligations, and that all those under our control comply with it.

This statement was approved by the Board of Allegion plc on June 4th, 2020.

 

By:         /s/ David D. Petratis                                                     

David D. Petratis

Chairman, President and Chief Executive Officer