Transparency in Supply Chains
Rheem will not tolerate human trafficking or slavery in its operations or its suppliers’ operations. Rheem encourages all of its employees to be vigilant regarding human trafficking and slavery in Rheem’s supply chain and to report any suspected human trafficking or slavery to the General Counsel. The company will not retaliate against employees who report suspected human trafficking or slavery in the Rheem supply chain.
The following disclosures are made pursuant to the California Transparency in Supply Chains Act of 2010 (Section 1714.43 of the California Civil Code) (referred to in this disclosure as the “Act”).
To what extent does, if any, does Rheem:
(1) Engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery? In 2012, as part of its standard supplier evaluation process Rheem will begin to evaluate the risk of human trafficking and slavery with respect to each supplier.
(2) Conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. At present, Rheem does not perform dedicated audits of suppliers to evaluate compliance with company standards for trafficking and slavery in its supply chains. Should circumstances in its supply chain warrant it, Rheem may implement such audits in the future.
(3) Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. In 2012, Rheem will begin to require its direct suppliers to certify that materials incorporated into the direct supplier’s product comply with the laws regarding slavery and human trafficking of the countries in which they are doing business.
(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. In 2012, Rheem will implement accountability standards and procedures for employees and contractors who fail to meet company standards regarding slavery and human trafficking.
(5) Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. In 2012, Rheem will develop and implement tools for training members of its supply chain workforce with respect to human trafficking and slavery.