California Transparency in Supply Chains Act Disclosure Statement

This statement is published in accordance with the California Transparency in Supply Chains Act (California Civil Code Section 1714.43).

Reliance Worldwide Corporation Limited and its subsidiaries (collectively “RWC”) are committed to shaping a more sustainable, just, and equal world.  RWC’s values are the foundational elements of the company and guide our business activities.  These values include passion, innovation, reliability, integrity, and simplicity.  RWC does not tolerate human rights abuses in any of its direct or indirect business activities.  Indeed, we want our employees and partners, whether directly in our operations or across our supply chains, to feel welcomed, respected, and safe at work.

RWC is a global provider of high quality, reliable, and premium branded water flow, control, and monitoring products and solutions for the plumbing and heating industry.  Our business operations include the design, manufacture, and distribution of these products including pipe, valves, fittings, and a range of ancillary products.  RWC is headquartered in Atlanta, Georgia with regional headquarters in London, United Kingdom, and Brisbane, Australia.

RWC regularly updates its governance structures, policies, and processes to meet our commitment to addressing Modern Slavery and human trafficking risk in our supply chains and operations.  Relevant group and regional policies related to our approach in addressing these issues include RWC’s: (1) Code of Conduct, (2) Global Whistleblowing Policy, (3) Americas Supplier Handbook, (4) Americas Supplier/Procurement Code of Conduct, (5) Global Ethical Code of Practice for Supply Sites Outside of Australia, (6) Global Corporate Social Responsibility Policy, and (7) EMEA Recruitment/Agency Workers Policy.

The California Transparency in Supply Chains Act requires a company to address five disclosure categories:  verification, audit, certification, internal accountability, and training.  RWC responds to each as follows:

• Verification.  RWC maintains a global supply chain that includes suppliers of raw materials (mainly brass bar and resins), components for assembly processes, and finished goods for sale. RWC undertook an assessment of the inherent modern slavery risks in its operations and supply chain and has developed a risk identification process that results in a risk-ranking score for each supplier of goods and services. The risk scores are used to inform and prioritize RWC’s management of Modern Slavery and human trafficking risk and ongoing due diligence over its operational activities and supply chains.  RWC applies the same methodology to screen and assess new suppliers.
   
• Audit.  RWC does not have formal processes in place for performing unannounced audits or regular on-site audits of its third-party suppliers.  However, RWC does perform limited audits by teleconference to review and clear any red flags or issues of concern identified through due diligence (e.g., request additional documents including a Modern Slavery Policy or discuss answers to questionnaires).  RWC will actively engage local third-party auditors to perform on-site reviews of its higher-risk suppliers as needed.
   
• Certification.  RWC requires its suppliers to provide it with a copy of their internal policy addressing Modern Slavery and human trafficking issues (including but not limited to child labour, deceptive recruiting, debt bondage, any form of human trafficking, slavery and servitude).  When suppliers do not have a documented policy, they are required to confirm that they will comply with all applicable laws related to Modern Slavery and human trafficking and acknowledge RWC’s policy as it relates to supplier partners.  In addition, RWC’s supplier agreements and supplier handbooks include provisions addressing Modern Slavery and requiring the supplier to comply with applicable laws.
   
• Internal Accountability.  RWC’s Code of Conduct expresses the company’s commitment to providing a workplace that is safe and free from any kind of discrimination, harassment, or intimidation.  A breach of the Code of Conduct may result in disciplinary action and penalties including dismissal and termination of employment or the engagement. Likewise, RWC’s group and regional policies, purchase orders, and supplier agreements require third-party suppliers to comply with applicable laws and standards.  A violation of law by a supplier can result in the termination of the relationship.  Lastly, RWC Global Whistleblowing Policy encourages employees to report instances of actual or suspected unethical, illegal, or fraudulent conduct by third parties or RWC employees.
   
• Training.  RWC has developed a training program for its employees to build knowledge and applied understanding of modern slavery and human trafficking risks. The training covers a range of modern slavery education topics, including how it affects businesses, actions to prevent modern slavery, legal requirements and RWC’s risk profile.