Responsible Supply Chain Statement 2024

Introduction

This Responsible Supply Chain Statement (“Statement”) is made by PMI WW Brands, LLC (“WW Brands”)1 and its subsidiaries, together representing WW Brands’ global business, including the Stanley 1913 brand and business. Policies and approaches associated with human rights and compliance are applied globally and cover all entities operating as WW Brands. This statement is made in accordance with the California Transparency in Supply Chains Act and the UK Modern Slavery Act (the “Acts”).

 

Business Structure and Values

WW Brands is committed to creating safe, inclusive, and respectful workplaces throughout all areas of our operations and our supply chain. Our dedication to these principles and the actions taken to achieve them are outlined in the Policy on Ethical Business Conduct and Supplier Code of Conduct (“the Code”), with additional information in the annual Stanley 1913 brand Impact Report.

WW Brands is a privately held company with direct operations consisting primarily of general corporate, product design, and sales functions. Sales are conducted through Stanley 1913’s online stores and both physical and online third-party retailers. Manufacturing of Stanley 1913 products is conducted by third-party suppliers. We develop strong relationships with our third-party suppliers and work closely with them to ensure implementation of and compliance with the Code.

 

Policies and Commitments

WW Brands implements its commitment to responsible business practices through global policies and practices. The policies are grounded in international human and labor rights standards and guidelines, including the International Labor Organization’s Declaration on the Fundamental Principles and Rights at Work. Throughout this document, the phrase ‘human rights’ is used to comprehensively refer to issues related to modern slavery, human trafficking, forced labor, and child labor.

The Supplier Code of Conduct defines the minimum standards each supplier is required to meet, including standards related to forced labor; harassment and abuse; fair wages, overtime, and benefits; hours of work; non-discrimination; freedom of association and collective bargaining; worker health and safety; and environmental protection.

The Policy on Ethical Business Conduct is applicable to all WW Brands employees and includes topics such as human rights, supplier relationships, bribery, and trade practices.

 

Supply Chain Management

Risk assessment

We engage third-party suppliers to manufacture Stanley 1913-branded products. To address potential risks of human rights issues arising from such engagements, we continuously evaluate the risks throughout our Tier 1 manufacturing suppliers, both before beginning relationships with suppliers and recurringly after the business relationships are established. These risks are monitored and assessed as follows:

• Sourcing location: Prior to entering a new sourcing location or introducing a new supplier, we conduct an assessment to identify relevant risks to inform decisions. This includes risks associated with the sourcing region, the industry or category of production, and the specific supplier. Based on the risk assessment, WW Brands is selective of the sourcing location or supplier, and develops targeted strategies to manage the risks identified as needed. We use independent resources, such as the US Department of State’s Trafficking in Persons Report and the World Bank’s Worldwide Governance Indicators, to support this risk assessment.
• Ongoing assessments: WW Brands conducts annual human rights and social risk mapping across its supply chain, which includes an assessment of general human rights and social risks by sector, as well as other applicable geography-specific risks. This assessment results in annual updates to our permitted sourcing country policy.
• Internal data and expertise: WW Brands employees are located in key sourcing regions and conduct regular facility assessments to ensure suppliers’ compliance with the Supplier Code of Conduct. Their experience, along with that of independent auditing firms, enhances our understanding of local risks.

Supplier selection and approval

WW Brands has an extensive process for vetting and approving new suppliers. We approve and begin working with a new manufacturing supplier only once they pass the supplier social compliance pre-assessment and – in many cases – a full social compliance audit. These audit processes are aligned with industry standards, such as those of Amfori BSCI, Sedex SMETA 4-Pillar, the Responsible Business Alliance, and Better Work.

Before entering a relationship with WW Brands, suppliers sign a contract that includes clauses requiring compliance with the Code and local laws. By signing this, suppliers are attesting to comply with the prohibition of human rights issues both within their own operations and those of their sub-vendors.

 

Monitoring

WW Brands uses both internal processes and external third-party audits to monitor compliance with our requirements and local laws. These affirmative measures take the form of announced, semi-announced, and unannounced on-site inspections of production facilities to measure supplier conformance with the Code. The facility monitoring program defines the monitoring procedures, tests, scope, and steps to be completed by auditors during the preparation for and execution of a facility inspection.

We require suppliers to self-report any known or suspected violations of the Code or local law or other unethical behavior to allow open discussion about corrective and remedial actions.

Additionally, we provide a grievance mechanism to enable individuals to report any unlawful or unethical behavior they witness by employees, representatives, or third-party vendors. WW Brands has a strict no retaliation policy for any individual who reports a potential violation in good faith.

If we identify or are provided evidence of an issue of non-compliance, it is promptly investigated. WW Brands expects the supplier’s facility management team to implement corrective actions immediately.

 

Accountability

Requirements to remediate are grounded in the overall best interests of the worker, international norms, and local laws. When appropriate, WW Brands provides for or cooperates in remediation within its supply chain. Any evidence of human trafficking, modern slavery, forced labor, or child labor is considered a zero-tolerance violation. Our approach to zero tolerance violations requires immediate and appropriate remedy, deep understanding of root causes, and renewed evaluation of the sourcing relationship. In cases of zero tolerance violations, WW Brands reserves the right to suspend or terminate the supplier relationship.

 

Training and capacity building

WW Brands provides training on the Code to employees and third-party suppliers at least annually. Suppliers are required to provide Code of Conduct compliance training to workers and contractors at least annually.

WW Brands additionally requires suppliers to implement and maintain a labor compliance plan that: (a) is based on internationally recognized standards, such as International Labour Organization’s (“ILO”) Indicators of Forced Labor in the supply chain; (b) provides training to supplier’s personnel and raises their awareness of issues related to forced labor; and (c) details the remediation supplier will provide in case of any violations. Supplier must inform its workers, agents, subcontractors, recruiters, and sub-suppliers about supplier’s policies that prohibit human rights violations.

 

Effectiveness

WW Brands utilizes several systems to assess the effectiveness of the policies and procedures in place to ensure that forced labor, child labor, and other labor law violations are not present in direct operations or supply chain. We regularly review the results of due diligence efforts, audits, and remediation measures. We track relevant performance indicators, such as audit results and grievances raised, and review all findings with suppliers on at least a quarterly basis as part of regular business reviews.

WW Brands regularly reviews and updates policies and procedures as needed, based on supply chain findings and external resources, to help ensure that its programs are effective at addressing these risks.

 

Attestation

In accordance with the requirements of the Acts, I attest that I have reviewed the information contained in the report for WW Brands. Based on my knowledge and having exercised reasonable diligence, I attest that the information in the report is true, accurate, and complete in all material respects for the purposes of the Acts.

 

Signature: Matt Navarro

Full Name: Matt Navarro

Title: Global President, PMI WW Brands, LLC.

Date: June 11, 2025