Kennametal Inc. 525 William Penn Place Suite 3300, Pittsburgh, PA 15219
Global Modern Slavery Statement
Global Modern Slavery and Human Trafficking Statement
Pursuant to the California Transparency in Supply Chains Act (2010), the Australian Modern Slavery Act (2018), the United Kingdom Modern Slavery Act (2015), Combating Trafficking in Persons, 48 C.F.R. § 52.222-50 and all other applicable legislation, Kennametal Inc., including all subsidiaries, divisions and affiliates thereof (“Kennametal”) has issued the below statement regarding Human Trafficking, Forced Labor and Modern Slavery (collectively “Modern Slavery”).
Modern Slavery is a crime and constitutes a violation of fundamental human rights. Kennametal has a zero-tolerance approach toward any form of Modern Slavery. We are committed to conducting our business responsibility and in the best interest of all stakeholders. The Company is taking proactive steps to detect and mitigate Modern Slavery risk across our global operations and supply chain.
Actions We Are Taking
Kennametal has implemented a global Modern Slavery compliance program modeled on the Organisation for Economic Co-operation and Development (“OECD”) Framework. The OECD framework calls for the establishment of management systems, risk identification, assessment and mitigation in the supply chain, and verification followed by reporting of relevant risks. We periodically review our Modern Slavery risk profile and make appropriate modifications to our approach, commensurate with our risk assessment.
Description of Kennametal’s Risk Identification, Assessment and Mitigation efforts, Due Diligence and Training
Consistent with guidance issued by the Attorney General of California in 2015 for the California Transparency in Supply Chains Act (2015) and the guidance issued under section 54(9) of the Modern Slavery Act by the Office of the Home Secretary of the United Kingdom (2015), the following section provides a brief description of the items referred to in the cited guidance. Items from Section 16 of the Australian Modern Slavery Act 2018 are also discussed below.
Kennametal has adopted a risk-based, phased approach to comply with applicable Modern Slavery legislation.
Our approach involves internally assessing our compliance risk profile across our global footprint. We use this risk assessment to identify focus areas for further risk mitigation efforts, including within our global supply base. Kennametal has also partnered with a third-party service provider to engage select supply partners to collect additional information regarding their labor force and use of contract labor from high-risk regions. Through this process, training is provided to identified suppliers encompassing the basics of Modern Slavery, as well as free resources, including, but not limited to, the National Human Trafficking Hotline.
Kennametal also asks that suppliers complete the electronic Labor Rights Template Lite (“eLRT Lite”), a free, open-source, MS Excel-based survey that contains questions used to indicate risk1. By returning the requested data, suppliers certify that the information they provided is accurate to the best of their knowledge. Receipt of the supplier-provided data then triggers risk assessment, where the data is audited and verified for validity. If information submitted by a supplier triggers a red flag, then further due diligence is conducted, leading to further risk mitigation, as needed.
If additional due diligence leads to risk mitigation, the supplier(s) is then considered higher risk and the second phase of Kennametal’s Modern Slavery compliance program is triggered, requiring further steps by Kennametal to engage and collaborate with the supplier to mitigate identified risk factors.
Kennametal is committed to reviewing and improving our Modern Slavery compliance program over time by refining, on a risk-appropriate basis, the scope of surveyed suppliers and the nature of requested information. We also intend to periodically re-survey previously assessed suppliers to detect changes in their risk profile.
Violations of Policy
Employees or suppliers determined by Kennametal to:
(1) engage in unlawful trafficking in persons during the period of performance of the contract;
(2) Procure commercial sex acts during the period of performance of the contract;
(3) Use forced labor in the performance of the contract;
(4) Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee's identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;
(5) Use misleading or fraudulent practices during the recruitment of employees;
(6) Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
(7) Charge employees or potential employees recruitment fees; or
(8) Unlawfully fail to provide return transportation or pay for the cost of return transportation upon the end of employment
will be subject to certain actions for violations of this policy. Such actions may include, but are not limited to, termination of applicable contract(s) or employment.
Reporting Questions and Concerns
Our team members, suppliers and all other stakeholders may report Modern Slavery questions and concerns at any time, and anonymously where allowed by law, to Kennametal’s Office of Ethics and Compliance by calling +1 412 248 8275, emailing email@example.com, or visiting https://secure.ethicspoint.com/domain/media/en/gui/48375/index.html.