Modern Slavery Statement

Zinsser is a manufacturer & supplier of speciality coatings, sealants and building materials in the building & construction sector. We are part of the Tor Coatings division, and our ultimate parent company is RPM International Inc.

RPM International Inc. is headquartered in Medina, Ohio in the United States of America. Shares of RPM’s common stock are traded on the New York Stock Exchange.

RPM International Inc. was founded in 1947, is a $7.3 billion, multinational company with subsidiaries that are world leaders in speciality coatings, sealants, building materials and related services. From homes and workplaces to infrastructure and precious landmarks, RPM’s market-leading brands are trusted by consumers and professionals alike to help build a better world. RPM has sales in over 170 countries and has over 17,000 employees worldwide. RPM strives to create a diverse and inclusive culture everywhere it operates.

RPM’s global supply chain consists of direct product suppliers, providing key commodities, raw materials, packaging and suppliers of non-product goods and services. The raw materials, components, items and systems required to manufacture RPM’s products and construction solutions are procured from suppliers around the world and vary from product to product.

RPM currently does business with approximately 5,000 product suppliers located in 50 countries and approximately 50,000 non-product suppliers worldwide. Approximately, 90% of all purchases are with RPM’s top 100 suppliers.

Zinsser is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains, including those of its sub-contractors and partners, are also free from slavery and human trafficking.

Zinsser acknowledges its responsibility to the Modern Slavery Act 2015 and the requirement to ensure transparency within the organisation and with their suppliers of goods and services.

We remain committed to conducting business ethically and responsibly, respecting and promoting human rights ,and opposing human trafficking and exploitation. Zinsser strives to operate in compliance with applicable laws where we do business by.

• Implementing policies and guidelines requiring equal opportunities, non-discrimination and non-harassment, the prohibition of child and forced labour.
• Complying with applicable health and safety and wage and hour laws and ensuring safe working environments and fair and living wages.
• Expecting our associates, suppliers, distributors, and applicators to operate in accordance with our Codes of Conduct.
• Respecting our associates’ right of freedom of association and collective bargaining in accordance with local laws.
• Offering a reporting hotline where individuals can report any ethical or employment concerns without retaliation.

Zinsser also support the U.N. Guiding Principles for Business and Human Rights, which respects and honours the principles of internationally recognised human rights.

Policies in relation to slavery and human trafficking

Zinsser Directors and senior management take responsibility for implementing this Policy statement, its objectives and shall provide adequate resources (including training) and investment to reduce the risk of slavery and human trafficking taking place within the organisation or its supply chains.

This policy statement will be reviewed annually, updated as appropriate, and published.

The following policies exist within the business that further reinforce Zinsser’s position on modern slavery and human trafficking:

• Human Rights Statement
• Supplier Code of Conduct
• Applicator & Distributor Code of Conduct
• Anti-Corruption & Bribery Policy
• Hotline and Non-retaliation Policy
• Third Party Due Diligence Policy
• RPM’s Values & Expectations of 168
• Equal Employment Opportunities Policy
• Recruitment/Agency Workers Policy

Due Diligence Processes

The organisation carries out due diligence processes to ensure slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of its suppliers in line with ISO9001, as well as performing due diligence on all third party vendors.

The organisation has not, to its knowledge, conducted any business with any other organisation which has violated modern slavery laws.

Imported goods from sources out the UK and EU have additional procedures and controls in place to ensure these sources are continually monitored for compliance. Zinsser will not support or deal with any business knowingly involved in slavery or human trafficking of any kind.

In accordance with section 54(4) of the Modern Slavery Act 2015, the organisation has taken the following steps to ensure compliance with the provisions of the Act:

• Risk Assessments: performed by RPM International Inc. on request of any RPM affiliate;
• Investigations/due diligence: to identify and asses the potential risks in the supply chain, performed by Zinsser / RPM International Inc. Legal and Compliance team or by individual departments;
• Risk Planning: creating action plans to address risk of modern slavery;
• Review of Supplier Contracts: review of the organisations purchasing policy to identify opportunities to mitigate or reduce any risks of modern slavery;
• In line with our Third-Party Due Diligence Policy, RPM conducts comprehensive Third-Party Due Diligence prior to engaging with new third parties. Initial reviews based on the third-party operational risk profile are conducted, including an assessment of industry, size, geographical location, and nature of third-party relationship.
• RPM has taken measures to strengthen its pre-existing Third-Party Due Diligence process throughout its supply chain by implementing a tailored screening system to identify and mitigate risks associated with its supply chain. Modern slavery risks are encompassed in this process, including both a World-Check screening to asses risk of specific breach of international laws and sanctions and Adverse Media-Check screening to asses additional reputational or integrity risk.

In addition, Zinsser Hotline and Non-retaliation Policy encourages all its employees, customers, and other business partners to report any concerns relating to the direct activities of its organisation or its supply chain without any retaliation, which includes the reporting of any circumstances that may give rise to a risk of slavery or human trafficking. The Hotline and Non-retaliation Policy is designed to make it easy for employees to make disclosures without fear of retaliation. Zinsser’s General Terms and Conditions of Purchase states (section 10: Compliance with Laws & Policies etc.) that the “Supplier represents and warrants that no Goods supplied under this PO will be manufactured by child or slave labour or by victims of human trafficking, and that Supplier complies with internationally recognised best practices to prevent and identify child, slave labour and human trafficking.”

Zinsser endeavours to carry-out its own recruitment activities and/or to only use reputable employment agencies to source labour and complete appropriate background checks. Personnel responsible for the recruitment activities in any of Zinsser’s business divisions are advised to adhere to this Policy by ensuring that strict verification of the potential employee’s right to work is carried-out before any offer employment is made.

Zinsser expects its subsidiaries, sub-contractors, and supply chain vendors to adhere to recruitment practices that ensure employment is voluntary. Where necessary and if required, demonstration of compliance with this Policy may be requested.

Risk assessment and management

As part of our initiative to identify and mitigate risk, Zinsser has systems in place to:

• Identify and assess potential risk areas in Zinsser’s supply chains.
• Mitigate the risk of slavery and human trafficking occurring in Zinsser’s supply chains.
• Monitor potential risk areas in Zinsser’s supply chains.
• Protect employees who report instances of modern slavery in line with the Hotline and Non-retaliation Policy.

All processes, procedures & system are reviewed and approved annually by senior management as part of Zinsser’s ongoing commitment to the Modern Slavery Act 2015.

KPI’s to measure effectiveness of steps taken:

The following key performance indicators (KPIs) are used to measure effectiveness in ensuring that slavery and human trafficking is not taking place in any part of the business or its supply chains:

• Requirement for all departmental managers, HR professionals and relevant purchasing and supply chain employees to complete training on modern slavery Regulations.
• Periodic reviews of existing supply chains, whereby the organisation evaluates existing suppliers through continuous monitoring, in line with Zinsser’s third party due diligence policy.
• Periodic business reviews including sourcing of raw materials and third-party supplier contracts.

Training on modern slavery and trafficking

To ensure a high level of understanding of the risk of modern slavery and human trafficking in Zinsser’s supply chains and business, training will be provided to all employees.

Zinsser also requires its vendors to communicate the expectations as outline in RPM’s Supplier Code of Conduct to all its employees. In line with the Supplier Code of Conduct, Zinsser reserves the right to audit should there be sufficient reason to suspect non compliance.

This statement and accompanying policies are made available to all employees when joining Zinsser. Any changes are communicated across Zinsser and training provided if required.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Zinsser slavery and human trafficking statement.