This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015, Australian Modern Slavery Act 2018 (Commonwealth) and the California Transparency in Supply Chains Act of 2010, and sets out the steps that Rockwell Automation, Inc. and its subsidiaries (hereafter “Rockwell Automation”) took during the fiscal year ending September 30, 2021 and continue to take to mitigate the risk of modern slavery and human trafficking within our business and supply chain.
Rockwell Automation, Inc. provides this statement for itself and on behalf of Rockwell Automation UK Ltd. (UK Modern Slavery Act 2015) and Rockwell Automation Australia Ltd (Commonwealth Modern Slavery Act 2018) which are the entities directly covered by a disclosure obligation in their respective jurisdictions.
This statement supports Rockwell Automation’s commitment to operate free from any kind of modern slavery with a zero-tolerance policy.
Consultation
Rockwell Automation, Inc. and its subsidiaries share the same core business operations and supply chains, as well as the modern slavery policies and risks. This joint statement has been prepared in consultation with group-wide key areas of our business including Strategic Sourcing, Compliance, and Legal, which operate globally across Rockwell Automation Inc. and subsidiaries, including Rockwell Automation UK Ltd. and Rockwell Automation Australia Ltd. The board of each of these subsidiaries is aware of the preparation of this statement and approved it.
Our Structure, Operations and Supply Chain
Rockwell Automation, Inc. is the world's largest company dedicated to industrial automation and information. It is a publicly traded company headquartered in Milwaukee, Wisconsin, USA and is the parent company for groups of companies doing business as Rockwell Automation, including Rockwell Automation UK Ltd. and Rockwell Automation Australia Ltd. It has more than 23,000 employees and its operations extend to over 100 countries worldwide. Rockwell Automation procures goods and services from over 50 countries.
Suppliers
Respect for human rights, fair labor practices, and humane working conditions are fundamental to our expectations of all suppliers and their subcontractors. Our global Supplier Code of Conduct is mandatory and prohibits forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slave labor, human trafficking and child labor.
During fiscal year 2021, there were no modern slavery or human trafficking reports identified with or raised by our suppliers. However, if such an issue were to arise, we would take appropriate actions together with the supplier to remediate the issue.
We routinely analyze global dispositions that impact our supply chain regarding forced labor prevention to make sure that we are complying with those regulations when applicable and that our internal policies are aligned to them. This fiscal year, we paid special attention to the Uyghur Forced Labor Prevention Act in the United States which impacts imports of items originating in the Xinjiang Uyghur Autonomous Region of China; the German Act which currently does not apply to any Rockwell Automation entity but served as a resource of good practices; and the CTPAT Program Trade Compliance Program to combat forced labor.
It is imperative for Rockwell Automation to take a proactive approach to ensure that not only our employees but all parts of our supply chain are educated in understanding the impacts of human trafficking and to take responsible actions to eliminate it. To achieve this objective, we pursued new technology and solutions to help us determine where to focus our efforts. This fiscal year the company invested in a recognized third-party due diligence supplier system for supply chain transparency and human trafficking due diligence. This system will automate our communication with suppliers to evaluate human trafficking risks, providing a high level of traceability to a greater number of suppliers. This system is currently in process of implementation and will be used during the next fiscal year. We are confident that this new tool will allow us to make a more conscious effort to combat modern slavery within our supply chain.
During this fiscal year, Rockwell Automation has been focusing its efforts to create a Responsible Supply Chain defined as the ethical design, planning, execution, control, and monitoring of supply-chain activities that have the objective of creating and managing commercial relationships that focus on the need for environmentally ethical and socially responsible products and services whose performance is measured globally as we seek to expand human possibility. These efforts focused on issues that have the potential to significantly impact our supply chain, including all forms of modern slavery. These ongoing efforts include a review of current policies and practices against international standards and best practices, described further in the Policies section below. To create a Responsible Supply Chain, we also receive feedback from an external consultancy (ERM) in supplier-related issues that significantly impact our supply chain, including modern slavery.
Policies
We have robust and monitored policies in place that aim to prevent and condemn modern slavery and human trafficking in our business and supply chains, which we re-evaluate as needed to ensure that they are effective and appropriate. We actively benchmark our Code of Conduct, Supplier Code of Conduct, PartnerNetwork Code of Conduct and other policies against international standards.
- Our Code of Conduct condemns all forms of forced compulsory labor, exploitative child labor, and participation in human trafficking by any person or organization, as well as any modern forms of slavery.
- Our Global Policy on Social Responsibility and Sustainability explicitly condemns all forms of compulsory labor, exploitative child labor, and exploitative working conditions.
- Our Global Policy People mandates that all employees be treated with respect and dignity, not suffer discrimination or harassment, and be safe at work. It also defines the resources that all employees and non-employees have for reporting any violation of the Code of Conduct and of any of our policies.
- Our Safety Policy aaffirms that the health and safety of our people is one of our top priorities and reinforces the Company’s commitment to provide a safe workplace where everyone can do their best work.
- As part of our continuous improvement, our Strategic Sourcing group has defined as a 2022 objective to evaluate the adoption of some or all of the Responsible Business Alliance Supplier Code of Conduct which establishes standards to ensure that working conditions in the electronics industry and its supply chains are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. Subject matter experts within the company will be engaged to support the effort.
These policies and Codes are published in multiple languages and apply to all employees and contractors. Non-compliance with these policies is taken seriously, and we are committed to ensuring corrective measures are in place.
Risk identification, risk assessment, and due diligence
We believe there is minimal risk of causing, contributing to, or being directly linked to instances of modern slavery within our operations. In conducting general due diligence, we have not found any areas of our business or supply chain to pose a significant risk for human trafficking or modern slavery.
During fiscal year 2021, the Company performed a risk assessment in India for the assessment of the different types of compliance risks we might be facing in that country including modern slavery risks. This assessment did not deliver any modern slavery risks within our operations in that country.
Sustainalytics, an Environmental, Social and Governance ranking agency, analyzed and rated the performance of our company addressing key ESG issues that can affect our company’s long-term performance and pose a financially-material risk. The Sustainalytics report incorporates human rights and whistleblower programs issues and served as an additional resource to help us identify any necessary actions to manage those particular ESG issues and opportunities in our human rights policy. Rockwell Automation’s ESG Risk Rating continues to be Low Risk.
In fiscal year 2020, we commenced the use of a modern slavery and forced labor supplier self-assessment questionnaire. This questionnaire was implemented to assist Rockwell Automation in assessing our suppliers in relation to modern slavery and forced labor risks, and to determine where additional monitoring, support, and investigation were required. As mentioned in the Suppliers section above, this fiscal year the company concentrated its due diligence and risk identification efforts on implementing a new system for third party due diligence that will allow us to solicit the supplier self- assessment questionnaire from an expanded number of suppliers and with greater traceability.
Accountability
At Rockwell Automation, every employee is responsible for respecting human rights. We encourage anyone with a concern to speak up without fear of retaliation and anonymously if desired. We have an accountable culture where issues can be reported through multiple channels, including to Human Resources, to any manager, to a Company lawyer or the Office of the Ombuds. We track and investigate all allegations regardless of the source and involve senior management if necessary. Employees and non-employees (including our suppliers) can report concerns to our Ombudsman (anonymously, if desired) by toll¬-free phone, fax, regular mail, email or a web-based tool. The options for how to contact the Ombudsman are available on our public website.
In case of any failure or violation of the Code of Conduct or applicable law, including modern slavery, the Company will take immediate and appropriate action to remediate and address the issue, including termination of employment or business relationships.
Effectiveness
During fiscal year 2021, we reviewed the following key performance indicators to assess the effectiveness of our efforts in addressing the risk of modern slavery in our business and supply chains:
