Global Modern Slavery Statement 2024

This Global Modern Slavery Statement 2024 (this “Statement”) is made by Otter Products, LLC, and its affiliates and subsidiaries, including, but not limited to, Otter Products EMEA Unlimited and Otter Products UK Limited (collectively, “Otter”) and is made pursuant to Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act of 2024, Section 54 of the UK Modern Slavery Act 2015, and the California Transparency in Supply Chains Act 2010. Otter is committed to preventing modern slavery, human trafficking, and other labour rights violations in its business operations and supply chains. This Statement outlines Otter’s approach and actions in fulfilling this commitment.

Organizational Structure

Otter is comprised of a global group of companies in the consumer electronics sector that design, source, package, and distributes (amongst other things) accessories for mobile devices.

Policies on Slavery and Human Trafficking

Otter is committed to building a supply chain free from modern slavery and human trafficking. Otter has robust policies in place that seek to prevent and condemn modern slavery and human trafficking in its business and supply chains including the following:

  1. Otter has adopted the Responsible Business Alliance Code of Conduct (the “RBA Code of Conduct”). The RBA Code of Conduct requires, among other things, that its direct suppliers ensure they do not engage in or support modern slavery or human trafficking. In addition, the RBA Code of Conduct requires suppliers to adopt and maintain terms of employment for their employees that comply with local law and requirements which include decency and appropriate labour standards that uphold human rights of workers and treat them with dignity and respect. Standards include appropriate labour, health and safety, environmental, ethics, and management standards. Subject matter experts within the Otter are engaged to support the effort.
  2. Otter condemns all forms of forced compulsory labour, exploitative child labour, and participation in human trafficking by any person or organization, as well as any modern forms of slavery.
  3. Otter mandates that all employees be treated with respect and dignity, not suffer discrimination or harassment, and be safe at work. It also defines the resources that all employees and non-employees have for reporting any violations of any of its policies.
  4. Otter’s Safety policies affirm that the health and safety of our people is one of our top priorities and reinforces our commitment to provide a safe workplace where everyone can do their best work. Otter expects its business partners to provide a safe workplace which is compliant with all local health and safety laws and is dedicated to implementing best practices in reducing workplace accidents and injuries.

Responsible Minerals Sourcing

Otter recognizes conflict minerals are often correlated with instances of modern slavery. Otter is dedicated to upholding ethical principles and social responsibility, aligning with laws that combat unethical practices in conflict affected and high-risk areas, including the Democratic Republic of the Congo.  Otter strives to comply with conflict mineral regulations and collaborate with our suppliers to responsibly source materials and components. Otter demands transparency and responsible sourcing practices from our suppliers, expecting them to investigate the origin and chain of custody of conflict minerals, disclose due diligence information upon request, and procure minerals from conflict-free sources that do not contribute to human rights abuses globally.

Due Diligence Processes for Slavery and Human Trafficking

Otter’s efforts to manage its supply chain relationships responsibly include the following actions:

  1. Verification of Product Supply Chains. Otter strives to establish close relationships with its suppliers and requires that they comply with all aspects of the RBA Code of Conduct including those aspects that relate to modern slavery and/or human trafficking.
  2. Supplier Audits. Otter reserves the right to verify supplier compliance with company standards and the RBA Code of Conduct. Otter utilizes independent third-party auditors to perform announced supplier audits and verify supplier compliance. If Otter becomes aware of any actions or conditions not in compliance with its company standards and/or the RBA Code of Conduct, Otter reserves the right to demand corrective measures which may include terminating the supplier’s contract.
  3. Certification Requirements for Direct Suppliers. Otter requires its direct suppliers to certify that materials incorporated into the products comply with the laws regarding modern slavery and human trafficking of the country or countries in which they are doing business. Otter presents the RBA Code of Conduct as a total supply chain initiative and requires suppliers to comply with laws regarding forced labour and human trafficking. Otter also requires suppliers to monitor the performance of their next tier suppliers against the requirements of the RBA Supplier Code of Conduct.<

    4. As part of the requirements of the RBA Code of Conduct and specialised labour standards, suppliers are required to develop appropriate management systems, which include policies, procedures, and associated documentation, to adhere to the requirements and any applicable laws and regulations, including those prohibiting modern slavery and human trafficking. Otter confirms the existence and maintenance of those management systems through our supplier audit program.

  4. Internal Accountability Standards and Procedures. Otter requires its employees to comply with company policies, including, but not limited to, policies prohibiting the use of modern slavery and human trafficking in its operations. Otter provides channels to report concerns about any potential violation of law or company policy including those related to modern slavery or human trafficking. Otter promptly investigates any such reports and takes all necessary corrective actions.
  5. Training. Individuals who have direct responsibility for supply chain management have access to trainings, information on all company policies, practices, and procedures designed to identify and respond to issues related to forced labour and human trafficking in the supply chain as well as to mitigate risks with the supply chain of products.

Further Steps

Otter recognizes that identifying and mitigating the risks of modern slavery and human trafficking requires on-going commitment and continual improvement. We will therefore continue working on our efforts to identify, assess, and address modern slavery risks within our operations and supply chains. These efforts include:

  1. Continuing to raise awareness by providing training to our employees and members of our supply chain.
  2. Conducting investigations of any non-compliance and taking prompt action as appropriate.
  3. Monitoring the effectiveness of our policies and procedures.
  4. Administering the modern slavery self-assessment questionnaire to a targeted and extended group of suppliers through the new platform for supplier due diligence.
  5. Continuing to monitor global regulations to combat modern slavery.

Approval

The Board of Directors of Otter Products, LLC has formally approved this Statement, applying to both Otter Products, LLC and its affiliated entities and subsidiaries.

Approval for this Statement:

OTTER PRODUCTS, LLC

Jonathan C. Richardson, Chief Executive Officer

OTTER PRODUCTS EMEA UNLIMITED

OTTER PRODUCTS UK LIMITED

Jonathan C. Richardson, Director

Date: 14th December 2023