ANTI-SLAVERY & HUMAN TRAFFICKING
For the most recently ended fiscal year the California Transparency in Supply Chains Act of 2010 and the U.K. Modern Slavery Act of 2015, require certain businesses to provide disclosures and take other actions concerning their efforts, to address the issues of slavery and human trafficking in their supply chains. Similarly, the Federal Acquisition Regulation provisions 52.222-50 and 52.222-56, are aimed at removing slavery and human trafficking from the U.S. Federal Government contracting supply chain.
EnerSys, and its subsidiaries worldwide (collectively, “EnerSys”, “Company”, “we” or “us”), understand the importance of responsible global corporate citizenship, and we consider it critical to engage with all stakeholders and use good judgment, to make ethical choices with integrity. We are committed to ensuring that all forms of modern slavery, including forced, compulsory labor and human trafficking, are excluded from our business and supply chain. Our business partners are expected to act in accordance with the highest standards of integrity and in compliance with all applicable laws and regulations. This Anti-Slavery and Human Trafficking Statement (“Statement”) addresses these statutes, rules and regulations and our commitment to the prohibition of slavery and human trafficking in our supply chain.
Many of our subsidiaries are not strictly subject to these statues or regulations. We have nonetheless undertaken an enterprise-wide approach to our efforts with respect to the anti-slavery and human rights concerns these statutes and regulations embody, and make this Statement on behalf of all of our companies worldwide.
We recognize that slavery and human trafficking can occur in many forms, including forced labor, child labor, domestic and indentured servitude, sex trafficking, and workplace abuse. Therefore, the terms “slavery and human trafficking” as used in this Statement include these various forms of coerced labor.
EnerSys is the world’s largest manufacturer, marketer and distributor of industrial batteries. We also manufacture, market and distribute related products such as chargers, power equipment, outdoor enclosures and battery accessories, and we provide related after-market and customer-support services for industrial batteries. We market and sell our products globally through a network of distributors, independent representatives and our internal sales force. Our business is highly decentralized with manufacturing locations and related supply chains throughout the world.
OUR SUPPLY CHAIN
Relationships between EnerSys and our suppliers must be based on mutual respect and integrity. We seek to maintain the highest standards and principles of business ethics, courtesy and competence in dealings and transactions with suppliers.
Our supply chain is complex, and there are limits to visibility beyond the first tier of suppliers. However, we strive for more complete traceability and transparency throughout our global supply chain. EnerSys has therefore established a comprehensive due diligence process.
EnerSys verifies product supply chains through multiple methods, including site evaluations, questionnaires, discussions, verification of government debarments and denied parties lists, among others. We participate and encourage active involvement in external organizations that assist with supply chain diligence, management and verification processes.
We require as a condition of contract that all suppliers agree to comply with all applicable laws and regulations. Suppliers outside the United States are required to comply with their local laws, as well as, the applicable laws of the United States.
OUR RELEVANT POLICIES
EnerSys has established a variety of relevant policies to address human rights:
1. Code of Business Conduct and Ethics, which sets out the legal and ethical standards of conduct with which EnerSys requires its personnel to comply. Amongst other things, it sets out our commitment to honest, ethical and fair working practices.
2. Corporate Social Responsibility and Human Rights Policy sets forth that all EnerSys business partners, including suppliers, are expected to comply with the principles described therein, including upholding human rights, supporting the elimination of slavery and working against corruption in all its forms.
3. Workplace Labor Rights Policy demonstrates our commitment to maintaining safe and inclusive workplaces that are based on recognized human rights, including the UN Guiding Principles on Business and Human Rights and Universal Declaration of Human Rights.
4. Our Code of Supplier Conduct reflects our commitment to our values and our expectation that all of our suppliers will adhere and embrace such values. It includes a commitment that all suppliers should ensure that all forms of modern slavery, including forced, compulsory labor and human trafficking, are prohibited and that they maintain safe and inclusive workplaces, based on recognized human rights. EnerSys further requires that suppliers act with reasonable diligence to ensure that any of their contractors, subcontractors, manufacturing facilities, labor providers, agents, partners, or subsidiaries, also comply with the principals, policies, and requirements expected of our suppliers.
We may terminate our relationship with any person or organization who does not comply with the above policies. Complete copies of these policies are available on our website at www.enersys.com under our Investor Relations or Corporate Social Responsibility webpages.
OUR ACCOUNTABILITY STANDARDS AND PROCEDURES
In order to prevent slavery and human trafficking in our business and supply chain we have implemented internal accountability standards and procedures.
Our Vice President, Global Procurement and Procurement Compliance Manager lead the development and implementation of the Company's efforts and work collaboratively with outside groups to promote responsible sourcing practices, including practices designed to prevent slavery and human trafficking. We also proactively communicate with external stakeholders and monitor trends and best practices in this area.
We undertake a periodic risk assessment of our supply chain to better understand the potential risks related to slavery and human trafficking. These assessments help us understand where human rights and labor issues may exist within our global supply chain so that we can prioritize and focus our responsible sourcing efforts.
EnerSys maintains whistleblowing procedures and anti-retaliation policies in order to empower and encourage employees to raise any concerns regarding compliance with this Statement, or any other concerns, without fear of retaliation. EnerSys provides access to an external and independent Ethics and Compliance Hotline. If the violation involves suppliers, appropriate action, up to and including termination of contracts will be undertaken.
Our Employee Training
EnerSys has developed training to ensure compliance with Company standards regarding this Statement. We will continue to develop and maintain training modules that support our commitment to human rights, including the prohibition of slavery and human trafficking, adherence to labor laws, adherence to truthful and trustworthy practices when dealing with employees, proper disclosure of information, and supply chain diligence, management and verification processes.
Our Effectiveness and Plans for Further Development
Enersys evaluates slavery and human trafficking risks as part of some of our audits conducted by our quality team. We will continue to review, reassess, and further develop our anti-slavery and human trafficking plans, not only to ensure compliance with the law but also to ensure that we fulfil our core values as expressed in this Statement.
Collectively, this statement, the policies, processes, and procedures described herein, are all designed to ensure at EnerSys and its suppliers at every level are committed to maintaining a workplace and supply chain free of slavery and human trafficking.