NSF International Modern Slavery Act Statement 2018
NSF International, along with its global subsidiaries (collectively, “NSF”), takes its social responsibilities very seriously and conducts its business in accordance with its core values of integrity, respect, commitment and creativity. However, business practices can always be improved, and NSF is committed to understanding more about modern slavery and improving our practices to ensure that slavery and human trafficking are not present in our operations or supply chain.
OUR BUSINESS AND SUPPLY CHAINS
NSF is a public health and safety organization registered under the laws of Michigan, United States. NSF has offices and labs in 30 countries.
NSF has more than 2,700 global employees. We deliver services in five core public health and safety areas: food, water, sustainability, health sciences and management systems. As a provider of professional services, our own supply chain is predominantly made up of professional service suppliers, including suppliers of office, laboratory and information technology equipment and support services.
INTERNAL POLICIES AND CONTROLS
NSF’s internal policies include our Code of Ethics, which we have recently revised to reflect our prohibition against modern slavery and trafficking. We also distribute our Code of Ethics to our independent contractors. In 2018, we will distribute our revised Code of Ethics.
Training on our Code of Ethics is provided to all new employees when they join NSF, and all employees are required to complete refresher training annually. Upon completion of the training, employees are required to sign an acknowledgment stating they understand and will comply with the Code of Ethics, and that they are aware that any violation will result in disciplinary action, up to and including discharge. We require our independent contractors to undergo training that covers the topics addressed in our Code of Ethics, and we make our Code of Ethics training available to our independent contractors if they choose to meet their training requirement in this manner. In 2018, all training on the Code of Ethics will address the revised Code of Ethics.
NSF operates an independent, third-party whistleblowing hotline, which is aimed primarily at our employees but is also available to any person who works within our supply chain. The hotline can be used to report any ethical, integrity or compliance issue, including human rights violations like modern slavery and trafficking. All reports received through our hotline are fully investigated by our Ethics Committee, which includes our CFO, our VP of HR and our General Counsel. The Ethics Committee reports regularly to our CEO and annually (or more often if warranted) to the Audit Committee of NSF International’s Board of Directors. We take any allegations that human rights are not being respected within our operations or supply chain extremely seriously.
ASSESSMENT OF MODERN SLAVERY RISK WITHIN OUR SUPPLY CHAIN
In the past year, we have increased our focus on modern slavery within our operations and our supply chain. We have reviewed our whistleblowing hotline to ensure it accommodates the reporting of modern slavery issues in our business and supply chains, and we have made our Ethics Committee and other constituents within NSF aware of the importance of immediately escalating any reports of modern slavery issues.
CONTRACTUAL CONTROLS
We are currently working on inserting a “compliance with laws” provision into our standard goods/services supply agreements which would require our suppliers to, among other things, comply with NSF’s Code of Ethics, and the anti-slavery and anti-trafficking provisions therein.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes NSF’s slavery and human trafficking statement for the financial year ending December 31, 2017. This statement is signed on behalf of the Board of Directors of NSF International by Kevan Lawlor.
Kevan P. Lawlor
President & Chief Executive Officer
NSF International
06/07/2018