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 2018 and is made pursuant to Section 54 of the UK Modern Slavery Act 2015 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 and Allegion Investments (UK) Limited.
Allegion is a $2.7 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 30 countries with 40+ sales, manufacturing and distribution sites. We employ over 11,000 associates and supply over 30+ 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, including our annual report, please visit: http://www.allegion.com.
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 original equipment manufacturer (OEM) supplied security related products.
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.
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, we are voting members of the Slavery & Trafficking Risk Template (STRT) Development Committee, the organization that maintains the standardized STRT which 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. In 2018, Allegion updated our standard vendor contract template to include additional clauses regarding human rights as recommended by the American Bar Association’s Working Group to Draft Human Rights Protections in International Supply Contracts.
Allegion Code of Conduct and Corporate Governance Documents:
Allegion Code of Conduct for Business Partners:
Corporate Social Responsibility:
Allegion Conflict Minerals Policy:
VERIFICATION AND DUE DILIGENCE
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 2018 and 2019, we campaigned on version 1.2 of the STRT and will implement version 1.3 in 2020.
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. The campaign was extended to the top 80 percent of our direct global supplier spend in 2018. In early 2019, our top spend logistics suppliers have been campaigned with plans to add indirect supplier spend later in the year.
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, the Allegion ethics and compliance functions and their work are reviewed and validated by both internal and external audits.
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 deliverables to comply with applicable local law and regulations. Additionally, our terms 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. We mitigate risk through a range of different approaches, including:
✔ New supplier screening, on-site-assessments (OSA) and qualification
✔ Long term supplier relationships and approved supplier lists (ASL)
✔ Supplier scorecards and supplier business reviews
✔ 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.
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.
Phone: United States and Canada: 855 807 3267
United Kingdom: 0 808 189 1053
Allegion employees who have direct responsibility for global supply management have received training on slavery and human trafficking, as well as related regulations, through our third-party provider’s online training. With this training platform, stakeholders will build their capacity to identify and respond to slavery and human trafficking risks.
In addition, 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.
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 5 June 2019.
By: /s/ David D. Petratis
David D. Petratis
Chairman, President and Chief Executive Officer