Human rights responsibility statement

It is Cook policy to comply with the laws and regulations applicable to Cook business activities around the world. The Cook value statement in our Code of Conduct addresses our corporate citizenship goals, which includes serving as a corporate role model for the betterment of society by being a sensitive employer, a contributor to the communities where we reside, and acting with the highest integrity in business dealings.

Cook has a comprehensive global Ethics & Compliance program and is committed to ensuring that our global operations comply with our own internal policies relating to human rights and also with any legal requirements, such as the California Transparency in Supply Chains Act and the U.K. Modern Slavery Act 2015 where applicable.

Cook continually improves its processes of verification, audit, certification, internal accountability, and training to assess and ensure that suppliers comply with Cook’s human rights responsibility goals. We engage third-party providers to help us with our efforts to ensure continuous improvement in this area while retaining management of internal controls and training.

Verification

Cook suppliers are asked to verify they operate in compliance with all applicable laws, regulations, governmental requirements, and industry guidelines in the countries in which they operate.

Audits

Cook plans to monitor suppliers based on an assessment of the level of risk of slave labor, human trafficking practices, or exploitation in the countries where the supplier operates.

Certification

Based on a risk assessment to include the material being sourced, Cook may request that suppliers certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the countries in which they are doing business.

Internal Accountability

Noncompliance with our company Code of Conduct may result in corrective action or termination of the supplier partnership, depending on the number and severity of noncompliance identified. We may work with suppliers to ensure corrective action plans resolve any instances of noncompliance.

Training

Cook employees receive annual training on the Code of Conduct. In addition, Cook is developing training programs on human trafficking for employees who have direct responsibility for supply chain management.