Policies, Procedures and Training Relating to Modern Slavery

Rentokil Initial plc and its subsidiaries are committed to acting in accordance with the law in every country in which we trade. Our companies and employees also operate under a number of policies to ensure a high standard of social, governance and ethical compliance, of which the cornerstone is the Code of Conduct. All policies are available internally on the Company’s intranet with key policies placed on the Company’s website.

Code of Conduct

The Company’s Code of Conduct (the Code) has been designed to help us achieve our responsibility as one of the world’s leading support services companies to set the highest standards of conduct. It is a fundamental commitment to comply with all applicable legal requirements and with high ethical standards. The Code outlines responsibilities to colleagues, customers and to the Company. It highlights our determination to embed our values of Service, Relationships and Teamwork and a culture of integrity across the Company. In 2019, the Company undertook a confidential survey of all colleagues and the question relating to ‘I have a good understanding of our values’ received a score of 90% (one percentage point above the global norm).

First introduced in 2011, the Code was updated in 2016 and is available to colleagues in multiple languages. The Code is accompanied by an online training programme which was refreshed most recently in October 2017. This is a compulsory training requirement for all new colleagues.

In the Human Rights section of the Code, we state that Rentokil Initial will under no circumstances make use of forced or coerced labour, servitude or slavery and will only employ individuals who are working of their own free will. It further states that no colleague will be deprived of identity papers, or be required to provide financial inducements to the Company, to facilitate their employment.

Policies

In addition to the Code of Conduct, the Company maintains policies on human rights, customers and suppliers, and rights of employees. Specific policies applicable to modern slavery include:

1.  Dignity at Work
2.  Group Diversity and Inclusion Policy
3.  Equal Pay
4.  Human Rights Policy
5.  Supplier Code
6.  Supplier Management Standard

All of these are available on our website at rentokil-initial.com/responsible-delivery/policies.

During 2019, over 16,000 Core Corporate Compliance training courses were completed by colleagues on the U+ online system.

Compliance to the specific policies listed above, as well as to the Code of Conduct, is checked and validated each year through a Letter of Assurance process, which is cascaded down through the Company from the Chief Executive. All senior managers are required to sign a letter to confirm they comply personally with key corporate policies and the Code, and that the colleagues for whom they are responsible are aware of and understand what is required of them, and that they are not aware of anyone within Rentokil Initial that is not complying to the Code. Details must be provided of any areas of non-compliance or uncertainty. The Audit Committee reviews the Letter of Assurance process and outcome.

Modern Slavery Awareness Training During 2019

The following training was carried out in 2019 across the Group:

1. The on-line training module for Modern Slavery Awareness that had been launched in 2018 by the U+ Training Academy was rolled out across the Company. An additional 1,947 colleagues have undertaken the on-line course in 2019, of which 87% passed the assessment test at the end of the module.
2.  Procurement Managers from all major markets received refresher training on the key aspects of modern slavery during the Global Procurement Conference in March 2019 as part of the introduction of the Supplier Code.
3.  Participation by the Global Product Quality Manager in the Ethical Trade and Human Rights Forum in 2019 to gain knowledge, share experiences and cooperate with other multi-nationals.

Assessment of Risk by Country of Manufacture

Products manufactured in India, Malaysia and Indonesia are perceived to have a higher element of risk from a modern slavery perspective, and are therefore assigned a more frequent audit cycle. It is, however, never forgotten that there are risks of enforced labour and poor treatment of workers in every country. The level of risk in each country of manufacture is assessed against the percentage spend with suppliers in that country:

_{Assessed using the Global Slavery Index 2018, based on estimated victims per 1,000 population.}

Read our Modern Slavery Statement

Sustainable Products

In Hygiene, hand wash liquids and foams are manufactured in-house, enabling a wider range to be produced, and ensuring full compliance with EU regulations, with full safety assessment and preservative efficacy data. Production is to the Good Manufacturing Practice standard specified for food processing and cosmetics manufacture and HACCP standards. The range is eco-certified, carrying Nordic Swan and Eco Flower labelling (except anti-bacterial soaps, because of their ingredients). Rentokil Initial Supplies is certified under ISO 9001 along with its sister manufacturing company, Dudley Industries. Both businesses are subject to audit under the Supplier Standard.

The Company’s paper supplies also carry the FSC, Nordic Swan and Eco Flower labelling as appropriate (with the exception of product such as Scrim paper, which has a polyethylene weave). The Eco Labelling range now includes EcoClear WC & Urinal Fluid products.

Sustainable Suppliers

Developing a collaborative supplier base is central to the Company’s supply chain strategy. Within Hygiene and Pest categories, there are monthly teleconferences with key suppliers to discuss performance against agreed KPIs.

Incentives for suppliers encourage and reward longer-term global partnerships. The Company is now consolidating the sourcing of pest control products across Europe items to maximise the procurement and supply chain synergies, minimise the potential for non-compliance by smaller suppliers and provide volume opportunities for preferred suppliers.

Global logistics management plays a key role in building a sustainable supply chain. The Company’s supply chain transportation footprint stretches from product suppliers through warehouses to branches and to end-user technicians and customers. This global network is continually reviewed to ensure that the most efficient supply route from supplier to end-user is employed. Shipping volumes are consolidated at the optimum location to provide the optimum service level at the lowest cost and environmental impact. Where volumes are high, shipments are made directly from supplier to the country warehouse or branch.

Delivering Safe Products

Sustainability risks for critical suppliers are identified and managed by the Global Product Quality Manager, whilst risks for major local suppliers are identified and managed by local Quality Managers and the country procurement team.

The Global Science Centre (The Power Centre) validates chemicals used in pesticides and fragrances to ensure they meet public regulations for all markets, such as REACH in Europe. Hardware and Equipment is validated to ensure compliance to local regulations such as the CE mark for products sold in Europe and the RoHS directive, which includes the verification of second and third-tier sources of components.

The product specifications set by the Marketing and Innovations team take explicit account of regulatory issues and responsible business practices. Where legacy products do not conform to the latest European regulations they are redesigned or reformulated to ensure compliance.