LEGAL NOTICE

ZWILLING J.A. HENCKELS (UK) LTD.

Registered Office address:
Ashleys
Invision House
Wilbury Way
Hitchin
Herts
SG4 0TY

Registered in England.
Company Registration Number: 05816563
VAT No. GB 915 838 401

Organisational Structure and Supply Chains Slavery and Human Trafficking Statement 2017 - ZWILLING J.A. Henckels AG

Werhahn Group

ZWILLING J.A. Henckels AG and its subsidiaries (“ZWILLING Group”) are part of the Werhahn Group with corporate seat at Neuss, Germany. The central management of the Werhahn Group is executed by Wilh. Werhahn KG. Wilh. Werhahn KG is a family-run business which places great value on a relationship of mutual trust with its employees, customers and business partners. Business activities of the Werhahn Group comprise three corporate divisions - Building Materials, Consumer Goods and Financial Services - with seven business lines.

The Werhahn Group is committed to act ethically and with integrity in its business dealings and to take the appropriate steps to preserve the fundamental rights and freedoms of its employees. Any activities such as forced or compulsory labor, human trafficking or other forms of slavery will not be tolerated within the Werhahn Group or its supply chains. Essential ethical values and standards of conduct are stipulated in Wilh. Werhahn KG’s Code of Conduct, which is applied within the whole Werhahn Group.

ZWILLING Group

ZWILLING J.A. Henckels AG’s headquarter is located in Solingen, Germany. ZWILLING J.A. Henckels AG has affiliated companies in twenty-two countries. Production companies of the ZWILLING Group are located in Germany, France, Italy, Belgium, Japan, India and China. ZWILLING Group’s core business is the production of high-quality kitchenware (such as knives, cookware, cutlery, etc.).

Supply Chains

Suppliers and sub-suppliers of ZWILLING Group are located in Europe, East Asia and Southeast Asia.

Employees and Organisational Policies

Employees

We can assure that all employees within the ZWILLING Group, whether temporary or permanent workers, work for us on their own free will. We ensure this by a transparent and reliable recruitment system applied on a global and local basis by always applying our general standards as defined in our Code of Conduct. When engaging recruiting agencies we ensure that they are professional, reliable and adhere to our social standards.

Werhahn Code of Conduct

The ZWILLING Group has implemented the Werhahn Code of Conduct within all ZWILLING Group companies on a worldwide basis. The Werhahn Code of Conduct explains the value system of the ZWILLING Group and defines the behavioural standards for all employees. It is based on the following core principles:

•We are human and straight in our dealings with each other, we are honest and loyal.

•We respect each individual’s dignity and identity and do not tolerate any discrimination, harassment or abuse.

•We bear personal responsibility.

•When attending to personal interests we take care that these do not conflict with the company’s interests.

•We comply with all laws and regulations (e.g. environmental protection, occupational safety, hygiene regulations).

•We do not tolerate corruption in any form (we do not bribe others or accept bribes ourselves).

•We compete fairly, do not give preferential treatment or discriminate against any business partners, and apply the rules of competition law in our dealings with competitors and customers.

Training

In addition to providing all employees of the ZWILLING Group with the Werhahn Code of Conduct, the ZWILLING Group also implemented an online training in the group’s core languages and provides regular face to face compliance trainings.

Helpline

The Werhahn Group furthermore provides their employees (including the employees of the ZWILLING Group) the opportunity to anonymously raise possible concerns with regard to a breach of the Code of conduct, statutory provisions or internal guidelines via a toll-free helpline. An eventual breach of human or other rights (e.g. through modern slavery or human trafficking) could also be reported via the helpline. Following the report of a potentially critical incident, such incident will be noted and comprehensively assessed by competent experts. Should the incident in fact constitute an infringement of the code of Conduct, statutory provisions or guidelines, appropriate measures will be taken immediately in order to settle the respective issue.

Relationship with Suppliers;

ZWILLING Code of Conduct for Suppliers

In addition to the Werhahn Code of Conduct ZWILLING has also implemented a ZWILLING Code of Conduct which is the basis for all supplier relationships, and needs to be signed by each supplier prior to entering into any supply relationship. The ZWILLING Code of Conduct sets out the social standards which need to be fulfilled by all ZWILLING Group suppliers and their sub-suppliers. These include amongst other things:

•Legal Compliance

•Prohibition of Discrimination, Child Labour, Forced Labour and Disciplinary Measures

•Freedom of Association

•Fair Remuneration

•Compliance with workplace health and safety as well as environmental standards.

Due Diligence Process

To ensure compliance with ZWILLING standards, the ZWILLING Group has implemented a due diligence process for its suppliers. In a first step ZWILLING determines whether the supplier has already been audited according to BSCI or SA 8000 standards. If the supplier has not been audited yet, ZWILLING’s further assessment is made on the basis of an extensive questionnaire covering all areas of social and environmental standards. Only if the results of the BSCI or SA 8000 audit or of the questionnaire are positive the supplier will be further evaluated.

If the results of the BSCI or SA 8000 audit or the interview are negative and cannot be cured within a short period of time the ZWILLING Group will not enter into a business relationship with the supplier. All results, including the ones of the delisted suppliers are being saved in a database in accordance with applicable data protection laws.

Supplier Audit / Factory Visits

ZWILLING Group carries out social compliance checks and audits at its suppliers on a regular basis. These are either conducted by own ZWILLING employees and/or where required by third parties engaged by ZWILLING. They include in particular extensive factory visits and additional detailed interviews with the management and employees.

Documentation of Failure / Termination of Business Relationship

Should a supplier fail to comply with applicable legal and/or ZWILLING social and environmental standards, ZWILLING requests immediate remediation. Respective incidents are being recorded within the ZWILLING data base, and a follow-up audit is being carried out. Should the supplier fail again, and in case the respective failure was not severe, ZWILLING will either provide its support to remedy the failure or end the business relationship. In case of severe failures ZWILLING will immediately terminate the business relationship.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes ZWILLING Group’s slavery and human trafficking statement for the financial year ending December 31, 2017.