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UK Modern Slavery Statement

WD-40 Company
Slavery and Human Trafficking Transparency Disclosure Statement
WD-40 Company Worldwide Corporate Structure and Supply Chain Relationships

WD-40 Company is a global business, with corporate headquarters in San Diego, California.
In addition to its United States domestic operations that also supplies products for markets in
Latin America and certain areas within the Asia-Pacific region, the company conducts
business in international markets through operating subsidiaries located in Australia (WD-40
Company (Australia) Pty. Limited), Canada (WD-40 Company (Canada) Limited), China (Wu
Di (Shanghai) Industrial Co., Ltd.) and the United Kingdom (WD-40 Company Limited). WD-40
Company manages its supply chain operations through each of these subsidiaries under a
consistent set of standards, policies and procedures.

WD-40 Company’s supply chain relationships can be divided into two groups

  • Tier 1 suppliers – direct suppliers of raw materials for the trade secret concentrate
    formulation for WD-40 Company Products and filling vendors for the supply of finished
    goods.
  • Tier 2 suppliers – indirect suppliers of raw materials and components to Tier 1 suppliers
    for the production of finished goods, and service providers using shift-based or
    temporary workers (i.e. warehousing and hauliers).

For Tier 1 suppliers, WD-40 Company has established standards and procedures to reinforce
our expectations toward social responsibility, including the company’s policies to prevent and
eliminate slavery and human trafficking in the company’s supply chain.

For Tier 2 suppliers, WD-40 Company employs a contract manufacturing supply chain
architecture with strong relationships based on mutual respect and trust. WD-40 Company
selects and approves suppliers for most raw materials and components, and distribution
methods. All suppliers are required to adhere to the company’s compliance standards, and
they are subject to verification of compliance and audit. Through this process, the company
believes the risk of slavery and human trafficking at its Tier 2 suppliers is very low.

WD-40 Company Policies and Procedures

WD-40 Company believes in and practices a strong set of Corporate Values, foremost among
those values are “We value doing the right thing” and “We value making it better than it is
today.” WD-40 Company and its global subsidiaries employ approximately 525 persons in
management, sales and support positions. There is no risk of slavery or human trafficking
within the company’s own global operations.

While WD-40 Company believes the risk of slavery or human trafficking in its supply chain is
low, the company nonetheless has a variety of mechanisms in place to assess and reduce
risks in its supply chain, including:

  • A Global Company Code of Conduct that addresses matters of corporate
    responsibility, including labour and workplace conditions.
    Manufacturing audits of WD-40 Company’s filling vendors.
  • A Global QMS (Quality Management System) that includes Non-Conformance
    monitoring, reporting and correction.
  • A Global Compliance Policy and Code of Conduct for WD-40 Company suppliers that
    is incorporated into all contracts for the supply of goods and services.
  • Risk assessments for consideration of independent third-party audit requirements for
    supply chain vendors

The following activities were undertaken during WD-40 Company’s fiscal year ended August
31, 2020 to address the problems of slavery and human trafficking in supply chains. These
continuing activities have been developed over a number of years. In keeping with WD-40
Company’s Corporate Value of making it better than it is today, risks associated with slavery
and human trafficking in the supply chain are regularly assessed in considering enhancements
to the company’s policies and procedures.

Verification and Risk Assessment

WD-40 Company annually maps all Tier 1 and Tier 2 suppliers to identify and assess risks
associated with labour practices, utilising the ethical supply chain management tool, Sedex,
where possible. In selecting both Tier 1 and Tier 2 suppliers, the company conducts diligence
activities to assess those risks and to verify that the supplier operations will comply with the
company’s standards as well as applicable anti-slavery and anti-human trafficking laws. The
company uses the annual risk assessment results to determine which Tier 1 and Tier 2
suppliers will be subject to audit during the year. The company has not employed third party
vendors in support of these verification and risk assessment activities.

Audits

Once supplier relationships have been established, Tier 1 filler vendors are subject to annual
audits to assure compliance with the company’s standards and applicable laws based on the
company’s verification and risk assessment conclusions. Audits may be performed by WD-40
Company Quality Assurance Department personnel or an independent third party. For Tier 1
suppliers of constituent chemicals and Tier 2 suppliers of other materials and components,
the company conducts periodic audits based on its assessment of risk, and the company may
also rely upon third party audits required by other customers of these vendors. The company
does not conduct unannounced audits. Where relied upon, some third-party audits may have
been unannounced.

Certifications

Terms and conditions for the purchase of goods and services from WD-40 Company’s Tier 1
suppliers provide for certifications of compliance with applicable anti-slavery and anti-human
trafficking laws in the countries in which they are doing business, as well as compliance with
the company’s anti-slavery and anti-human trafficking standards included in the company’s
Global Compliance Policy and Code of Conduct. The company also requests such
certifications from certain Tier 2 suppliers as a condition to continued selection and approval
of such suppliers as supply chain vendors for the company’s products.

Accountability

WD-40 Company maintains internal accountability standards and procedures for employees
and suppliers who fail to comply with company standards or local anti-slavery and anti-human
trafficking laws and regulations. The company’s Code of Conduct requires conduct consistent
with WD-40 Company’s Corporate Values, including standards for fair labour and workplace
practices. Supply chain vendors are required to adhere to specific anti-slavery and anti-human
trafficking laws and company standards included in WD-40 Company’s Global Compliance
Policy and Code of Conduct. Employees are subject to discipline, up to and including
termination of employment, for violations of the company’s Code of Conduct. Suppliers may
be expected to take corrective actions to address non-compliance findings in audits or
upon investigation by WD-40 Company’s Quality Assurance Department. In appropriate
circumstances, the company may terminate a supplier’s contract or discontinue orders for
goods or services.

Training

In the past fiscal year, all WD-40 Company employees received Code of Conduct training.
Quality Assurance Department employees charged with the oversight of supply chain vendors
received instruction as to risk assessment protocols, audit standards, and compliance
certification requirements.

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