SC Johnson Statement on Slavery and Human Trafficking
For more than a century, SC Johnson has been guided by certain basic principles about the people to whom we are responsible and whose trust we want to earn. Chief among these are integrity, responsibility and respect. We have a zero-tolerance policy for human trafficking or slavery, and we unequivocally support the human rights of all our employees and the employees of our global suppliers.
In keeping with this commitment, we support the United Nations Declaration of Human Rights, the CGF Social Resolution on Forced Labour, its priority principles, and the International Labour Organization core standards on forced labor, child labor, freedom of association and discrimination. We also support the California Transparency in Supply Chains Act of 2010 (the “CA Act”) and the United Kingdom’s Modern Slavery Act 2015 (the “U.K. Act”), and their intent to prevent and eliminate slavery and human trafficking from global supply chains by increasing transparency.
About the Acts
The CA Act requires companies that do business in California to disclose what efforts they make to keep their supply chains free of these human rights violations. Similarly, the U.K. Act requires companies that conduct business in the U.K. to produce an annual statement setting out the steps they have taken to ensure that slavery and human trafficking are not taking place in their supply chains or their own business.
SC Johnson addresses these concerns through our internal standards, policies and practices, our Supplier Code of Conduct, and the practices these require.
Supplier Code of Conduct
SC Johnson’s Supplier Code of Conduct specifies our requirements for our suppliers in four key areas: Human Rights and Labor; Safety, Health and Environment; Sustainability; and Business Ethics.
The Code was developed with consideration for recognized global standards and guidelines including The Global Social Compliance Programme Reference Code, The International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work, The United Nations’ Global Compact and The United Nations’ Universal Declaration of Human Rights. We support the efforts of such organizations that seek to improve working conditions. The SC Johnson Supplier Code of Conduct addresses the following labor and human rights issues, among others:
- Prohibition of forced labor – suppliers must never use forced labor or human trafficking in any form, whether prison, slavery, indentured, bonded or otherwise.
- Minimum age requirement – suppliers must not employ any person below the age of 15 or the national minimum age for employment, whichever is higher. If the minimum age for employment is set at 14 for a particular country in accordance with the International Labour Organization standards, exceptions may be made.
- Compensation and minimum wage requirements – suppliers must provide each employee at least the minimum wage.
- Legally mandated benefits – suppliers must provide each employee, at a minimum, all legally mandated benefits.
- Maximum work hours – suppliers must comply with legally mandated work hours
- Environmental, health and safety requirements – suppliers must have written safety, health and environmental guidelines, comply with local safety, health and environmental laws and regulations, and provide personal protective equipment.
- Immigration/qualified to work laws – suppliers must comply with applicable immigration and related laws to ensure that employees may work in the country where the employees are providing services.
How We Verify Compliance
SC Johnson suppliers must stay up-to-date with best practices and maintain all documentation and records required to demonstrate compliance with the standards in our Supplier Code of Conduct. They also must submit to audits or inspections as required by SC Johnson, and certify their respective compliance with the Code.
Along with our internal processes and supplier-provided information, we partner with Suppliers Ethical Data Exchange (SEDEX) to identify, assess and manage any social or ethical risks in our supply chain. We use independent, third-party audit firms to conduct onsite audits, based upon the SMETA 4 pillar protocol. SC Johnson’s Supplier Code of Conduct allows us to conduct audits, without prior notice and with either SC Johnson personnel or independent third parties. We also offer an Ethics and Compliance Hotline through which concerns can be reported anonymously, if desired. The hotline enables any person with a concern about a matter relating to our Supplier Code of Conduct to report it 24 hours a day, seven days a week.
Major suppliers are contractually obligated to comply with the SC Johnson Supplier Code of Conduct, under our supply agreements. We also intend to continue to increase the portion of our purchases that are contractually subject to the Code. In addition, our purchase orders contain requirements that suppliers must comply with all applicable laws and regulations. Suppliers that have contractually committed to comply with the SC Johnson Supplier Code of Conduct must certify that the goods and services they provide to our company are manufactured in compliance with those standards, and with all applicable laws and regulations in the jurisdictions where they are produced. We will require re-certification by suppliers on a periodic basis.
Internal Accountability and Training
Doing the right thing and acting with integrity are the personal responsibility of everyone at SC Johnson. Our Global Procurement team leads our efforts to review suppliers on a risk-based approach and requires they submit to audits or inspections, and certify their work as required. If a supplier fails to comply with any aspect of the Code, we require that the supplier take the appropriate remedial actions. If the issue is serious enough, or if appropriate corrective actions are not taken in a timely fashion, SC Johnson can terminate the relationship with the supplier. SC Johnson expects every employee to act in a legal and ethical manner consistent with This We Believe, company policies and laws. On an annual basis, every management employee affirms their compliance with our company Standards of Conduct. In addition, we provide targeted training on the SC Johnson Supplier Code of Conduct and our Responsible Sourcing program to the people accountable for those areas of greatest risk.
We All Work Together
Protecting human rights requires collaboration and transparency at every step. That is an expectation for every SC Johnson employee and supplier, and it is a commitment we work vigorously to protect through our standards, policies and practices. Learn more about what we do and how we do it in our Sustainability Report and our Supply Chain Transparency section of our website.
- H. Fisk Johnson, Chairman and CEO
This statement is published October 2019 under Section 54 of the UK Act for SC Johnson Europe Sarl, S.C. Johnson Limited, SCJ UK Finco Ltd and SC Johnson Professional Ltd.