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California Transparency in Supply Chains

Cabinetworks Group Michigan, LLC California Transparency in Supply Chains

This disclosure is made in accordance with the California Transparency in Supply Chains Act (SB 567) which requires that companies disclose certain matters with respect to their efforts to ensure that their supply chains are free from slavery and human trafficking.

Cabinetworks Group Michigan, LLC and its subsidiaries have a longstanding commitment to the ethical and responsible sourcing of goods and supplies for Cabinetworks Group Michigan, LLC and its subsidiaries.  The Cabinetworks Group Michigan, LLC Supplier Business Practices Policy (SBPP), which is published at www.mascocabinetry.com/suppliers-policy/, formalizes that commitment by requiring, among other things, that our suppliers respect our standards and those of our customers, including with regard to compliance with laws, human rights, child labor, human trafficking, slavery, wages and benefits, excessive working hours, corporal punishment, discrimination, safe and clean workplaces and other labor and employment standards.

 

Verification of supply chains and auditing of suppliers to evaluate supplier compliance and address risks with respect to human trafficking and slavery.

Cabinetworks Group Michigan, LLC has a formal system for reviewing and accepting new vendors.  For vendors located outside the United States, Canada and Western Europe, this program requires a physical review of each new factory to ensure it meets at least baseline requirements with respect to applicable laws and working conditions, including laws against human trafficking and slavery.  Additionally, the Cabinetworks Group Michigan, LLC Purchase Order Terms and Conditions for Cabinetworks Group Michigan, LLC and its subsidiaries (published at http://mascocabinetry.com/suppliers-terms-and-conditions/) requires compliance with applicable laws as well as the standards and requirements set forth in the SBPP.

 

In addition to the process for selecting new vendors described above, Cabinetworks Group Michigan, LLC engages in verification of the practices of its existing supplier base (other than suppliers located in the United States, Canada and Western Europe) through periodic announced audits to assess risks and ensure compliance with applicable laws and conditions, including laws governing human trafficking and slavery.  These audits are conducted by third parties for suppliers located in other countries.  If significant issues are raised by an audit, the company may also conduct a follow-up unannounced audit to address the initial findings.

Cabinetworks Group Michigan, LLC maintains an internal scoring system with respect to its periodic audits of suppliers and records the results in an internal database.  Cabinetworks Group Michigan, LLC further investigates all reported instances of non-compliance and takes appropriate action to help ensure that our SBPP standards and applicable laws are observed.  

 

Certifications from suppliers that materials incorporated into Cabinetworks Group Michigan, LLC products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Cabinetworks Group Michigan, LLC selection and continued use of suppliers is based on the following standards described in our SBPP with respect to all goods that we purchase:

1.    Comply with all applicable laws and regulations.

2.    Protect against the use of workers younger than the minimum age required by law.

3.    Protect against the use of forced labor (i.e., human trafficking and slavery).

4.    Provide appropriate wages and benefits as required by law.

5.    Protect against excessive working hours that exceed local laws or business customs.

6.    Protect against physical and mental punishment of workers.

7.    Protect against unlawful discrimination against workers and encourage employment based on ability.

8.    Respect workers’ rights to associate freely.

9.    Maintain safe and clean workplaces, including any residential facilities, in compliance with the law.

10.  Protect our confidential and proprietary information.

11.  Provide us all requested information regarding the use (or non-use) of Conflict Minerals.

We will not knowingly work with suppliers that do not respect these standards and those of our customers.  We will periodically assess our supplier’s compliance with these standards and those of our customers.  Any reported non-compliance will be investigated and appropriate action will be taken.  These standards apply whether the supplier is a be Cabinetworks Group Michigan, LLC and its subsidiaries or a third party.

Cabinetworks Group Michigan, LLC internal accountability standards and procedures for employees or contractors failing to meet company standards regarding trafficking and human slavery and training for employees and management who have direct responsibility for supply chain management.

Cabinetworks Group Michigan, LLC maintains internal accountability standards for employees through its legal and ethical compliance program (the "Code of Business Ethics"), which focuses on areas of ethical risk, and helps foster the Cabinetworks Group Michigan, LLC culture of honesty, accountability and transparency.  Further, the SBPP pledges that Cabinetworks Group Michigan, LLC will avoid working with suppliers that do not respect our standards and those of our customers.  If an employee is in violation of our Code of Business Ethics or if a supplier is acting in violation of the SBPP, we will (in certain egregious situations) terminate such employee or supplier, or we will work with them to remedy the violation.  If the effort to remedy the violation is unsuccessful, we will evaluate our business relationship with that supplier or employee and take appropriate corrective action.  Corrective action may include cancellation of an affected order, prohibition on further use of a facility or supplier, termination of employment and reporting the violation to the proper authorities.  If a supplier refuses access to our auditors, the relationship with that supplier will be terminated.

Cabinetworks Group Michigan, LLC believes that education and training are critical components to ensuring that our standards are met and that human rights within our supply chain are respected.  All salaried employees, including those with responsibility for supply chain, are required to certify annually their compliance with the Cabinetworks Group Michigan, LLC Code of Business Ethics and complete on-line training.  The Cabinetworks Group Michigan, LLC Code of Business Ethics includes the requirement to comply with all laws in all places where Cabinetworks Group Michigan, LLC does business, and a violation of the Code may result in penalties, including termination.  Additionally, Cabinetworks Group Michigan, LLC periodically trains each of its employees and managers with responsibility for supply chain management with respect to the applicable requirements of, and compliance with, our SBPP, including with respect to human trafficking and slavery.