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Anti-Human Trafficking Statement

INTRODUCTION

Allegion believes businesses have a central role to play in respect for human rights, combating modern slavery and human trafficking. 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 forced labor or slavery.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and the California Supply Chains Act of 2010 (SB 657), which require Allegion to disclose our efforts to combat such issues, and details the steps Allegion has taken to ensure slavery and human trafficking are not taking place in our business and supply chains.

This statement constitutes our slavery and human trafficking statement for the fiscal year 2017. We will review and publish this statement annually.

UPDATES AND IMPROVEMENTS

Since Allegion’s last report in June 2017, our company has:

  • Updated our employee Code of Conduct to include Allegion’s commitment to uphold human rights;
  • Nominated an Allegion employee for and accepted a position of participation on the Social Responsibility Alliance’s (SRA) Slavery & Trafficking Risk Template Development Committee;
  • Made numerous charitable contributions to organizations supporting human rights, such as monetary donations to protective housing for orphans in Latin America and providing a complete security installation to a residence for victims of human trafficking in the United States; and
  • Included supply chain transparency review and human rights training as part of M&A due diligence and integration planning.

ORGANIZATIONAL STRUCTURE  

Allegion is a $2.4 billion global technology and manufacturing 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 portable security needs, homes and businesses.

Our global footprint spans more than 30 countries with 31 production facilities and several distribution centers.  We employ 10,000+ associates and supply over 30 product brands to ~130 countries across the globe.

Our global headquarters is located in Dublin, Ireland with three regional headquarters located in the Americas (Carmel, Indiana), Asia Pacific (Shanghai, China) and EMEIA (Faenza, Italy).  To learn more about our business, please visit our corporate website.

SUPPLY CHAIN

Our domestic and international supply chains include the sourcing of both raw materials and components principally related to the manufacturing of mechanical and electronic security products as well as OEM supplied security related product. Materials and components are sourced from Asia, Europe, Middle East and the Americas. For more information on the management of Allegion’s supply chain, please visit our Supplier Portal.

ORGANIZATIONAL POLICIES  

Confirmation of 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), The Society of Corporate Compliance and Ethics, 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 also expects that our business partners, including our suppliers, vendors, consultants, and contract labor to adopt and enforce standards similar to those defined in the following policies and initiatives.

VERIFICATION AND DUE DILLIGENCE

Verification and Risk Assessment:

Allegion is partnered with a third-party provider, Assent Compliance, to assist with the identification and risk mitigation of modern slavery throughout our global supply chain.  Our tier one 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 formerly known as the HTRT) available at www.sraglobal.org

This screening approach enables us to assess the strength of the supplier’s risk mitigation activities in relation to their risk exposure from 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 supplier 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.  

Following the launch of our pilot program in 2016, we launched a screening campaign with our ASL (approved supplier list). Allegion also used our GSI (global slavery index) to identify geographical high-risk direct spend suppliers in Q4 of 2017.  The campaign was extended to the top 80 percent of our direct global spend in Q1 of 2018 with the goal of completing a full assessment of our direct global spend by the end of Q4 2018. In 2019, our ASL indirect spend and logistics suppliers will be included.

Internally, Allegion has started a review of all recruiting firms.

Internal Accountability:

Allegion annually conducts Code of Conduct awareness training and 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.  In addition, certain elements of our program are validated by internal audits.

Supplier accountability

Allegion is committed to working with our suppliers to both mitigate and address any identified risk. We 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 self-assessment campaign audits;
  • Internal audit on supplier sites showing high risk with the STRT 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; and
  • 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. This confidential, non-retaliatory resource is available for any internal or external stakeholder to inform Allegion of concerns or report alleged non-compliance with our Code of Conduct and Ethical Sourcing Policies and Guidelines by phone or by sending an e-mail to the Helpline provider.

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 (other international phone numbers available online and posted at each Allegion facility)

CAPACITY BUILDING/TRAINING

The importance of human rights and anti-trafficking efforts continues to be communicated internally and with our business partners.

Allegion’s 2018 harassment and discrimination campaign addresses this topic to raise global internal awareness. We have already trained employees with direct supply chain responsibilities, as well as our audit, compliance, and trade compliance functions and intend to continue this internal training for other groups, prioritized by risk. Through this training, employees build their capacity to identify and respond to slavery and human trafficking risks within our operations and supply chain. In 2018, we will work to expand our training program with continuing education conferences and webinars through Assent for our supply chain risk management team, vendors and others (as identified).

CLOSING/ RESPONSIBILITY FOR THE POLICY

The Allegion Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that it is complied with by those under our control.

This statement was approved by the Board of Allegion, on June 6, 2018.

 

By:         /s/ David D. Petratis                                                     

David D. Petratis

Chairman, President and Chief Executive Officer