California Transparency in Supply Chains Act Disclosure Statement
About this Statement
This statement is published in accordance with the California Transparency in Supply Chains Act (California Civil Code Section 1714.43).
Reliance Worldwide Corporation Limited and its subsidiaries (collectively “RWC”) are committed to shaping a more sustainable, just, and equal world. RWC’s values are the foundational elements of the company and guide our business activities. These values include passion, innovation, reliability, integrity, and simplicity. RWC does not tolerate human rights abuses in any of its direct or indirect business activities. Indeed, we want our employees and partners, whether directly in our operations or across our supply chains, to feel welcomed, respected, and safe at work.
RWC’s Business and Structure
RWC is a global provider of high quality, reliable, and premium branded water flow, control, and monitoring products and solutions for the plumbing and heating industry. Our business operations include the design, manufacture, and distribution of these products including pipe, valves, fittings, and a range of ancillary products. RWC is headquartered in Atlanta, Georgia with regional headquarters in London, United Kingdom, and Brisbane, Australia.
RWC regularly updates its governance structures, policies, and processes to meet our commitment to addressing Modern Slavery and human trafficking risk in our supply chains and operations. Relevant group and regional policies related to our approach in addressing these issues include RWC’s: (1) Code of Conduct, (2) Global Whistleblowing Policy, (3) Americas Supplier Handbook, (4) Americas Supplier/Procurement Code of Conduct, (5) Global Ethical Code of Practice for Supply Sites Outside of Australia, (6) Global Corporate Social Responsibility Policy, and (7) EMEA Recruitment/Agency Workers Policy.
The California Transparency in Supply Chains Act requires a company to address five disclosure categories: verification, audit, certification, internal accountability, and training. RWC responds to each as follows:
- Verification. RWC maintains a global supply chain that includes suppliers of raw materials (mainly brass bar and resins), components for assembly processes, and finished goods for sale. In 2019, RWC retained the services of an external consultant to review its existing suppliers of goods and services and to prepare an initial risk-ranking for each. The risk scores were used to inform and prioritize RWC’s management of Modern Slavery and human trafficking risk and ongoing due diligence over its operational activities and supply chains. RWC intends to apply the same methodology moving forward to screen and assess new suppliers.
- Audit. RWC does not have a formal process for performing unannounced audits of its third-party suppliers and has not yet performed on-site audits of its suppliers. However, RWC does perform limited audits by teleconference to review and clear any red flags or issues of concern identified through due diligence (e.g., request additional documents including a Modern Slavery Policy or discuss answers to questionnaires). RWC is also in the process of engaging local third-party auditors to perform on-site reviews of its higher-risk suppliers.
- Certification. RWC requires its suppliers to provide them with a copy of their internal policy addressing Modern Slavery and human trafficking issues. When suppliers do not have a documented policy, they are required to confirm that they will comply with all applicable laws related to Modern Slavery and human trafficking. In addition, RWC’s standard Purchase Order template and supplier agreements include a clause addressing Modern Slavery and require the supplier to comply with applicable laws.
- Internal Accountability. RWC currently maintains limited accountability standards or procedures that pertain directly to Modern Slavery and human trafficking. However, RWC’s Code of Conduct expresses the company’s commitment to providing a workplace that is safe and free from any kind of discrimination, harassment, or intimidation. A breach of the Code of Conduct may result in disciplinary action and penalties including dismissal and termination of employment or the engagement. Likewise, RWC’s group and regional policies, purchase orders, and supplier agreements require third-party suppliers to comply with applicable laws and standards. A violation of law by a supplier can result in the termination of the relationship. Lastly, RWC Global Whistleblowing Policy encourages employees to report instances of actual or suspected unethical, illegal, or fraudulent conduct by third parties or RWC employees.
- Training. RWC does not currently provide formal Modern Slavery or human trafficking-related training for its employees, managers with supply chain responsibilities, or third parties. However, employees responsible for engaging suppliers are provided informal training and communications on Modern Slavery risk and how to identify red flags.