Modern Slavery Transparency Statement
NSF International, along with its global subsidiaries (collectively, "NSF") takes its social responsibilities very seriously. We conduct our business in accordance with seven core values, including respect for one another, and in accordance with our Code of Ethics, which sets out our commitment to treating all individuals with the rights and dignity to which they are entitled. NSF is committed to continuous improvement, and we are dedicated to understanding more about modern slavery, and to improving our practices to ensure that modern slavery and human trafficking are not present in our operations or our supply chains.
Our Structure, Business, and Supply Chains
NSF is a public health and safety organisation registered under the laws of Michigan, United States. NSF has offices and laboratories in 29 countries located in Africa, Asia, Europe, Latin America, the Caribbean, the Middle East, North America, and Oceania. Manufacturers, regulators and consumers look to NSF for the development of public health standards and certification programmes that help protect the world’s food, water, consumer products and environment. Our mission is to protect and improve global human health. As an independent, accredited organisation, our standards group facilitates the development of standards, and our service groups test and certify products and systems. We also provide auditing and risk management solutions for public health and the environment.
NSF employs more than 2,700 global employees and contracts with independent contractors and independent laboratories in each of the regions in which we operate. We employ temporary workers from time to time; these are professional or highly skilled workers such as laboratory technicians or information technology personnel.
We deliver professional services in five core public health and safety areas: food, water, sustainability, health sciences, and management systems. As a provider of professional services, our employees and independent contractors consist of highly-skilled professionals, including auditors, laboratory personnel, scientists, and professional office personnel. We do not manufacture products, and do not own manufacturing facilities or employ any manufacturing personnel.
Our Supply Chain
Our supply chain (parts of which are located in each region in which we operate) is predominantly made up of suppliers of professional services such as laboratory work, information technology services, and other similar support services. We also purchase office, laboratory, and information technology equipment and related supplies. We are a reseller of one tangible product--“smart” glasses. We do not manufacture the glasses, but resell them on behalf of a reputable global manufacturer.
Responsibility for Implementation and Management of Our Modern Slavery Policies
Our Ethics Committee, comprised of our Chief Legal Officer, our Chief Human Resources Officer, and our Chief Financial Officer, is responsible for the implementation and management of our modern slavery policies. Our Ethics Committee reports regularly to our Chief Executive Officer, and annually (or more often as the need may arise) to the Audit Committee of the NSF International Board of Directors. Kevan Lawlor, our President and Chief Executive Officer, signs our Modern Slavery Act Transparency Statement on behalf of our board, after approval by the board. There have been no changes in our process since our 2019 statement.
Policies Relating to Slavery and Human Trafficking
In 2018, we revised our Code of Ethics to add our express prohibition against modern slavery and trafficking. Related, we added a modern slavery/trafficking “drop down item” as an option employees and others outside the enterprise can report on through our anonymous online ethics reporting “hotline.” The anonymous reporting procedure has remained available during the pandemic. Our Code of Ethics also includes provisions expressly allowing freedom of association and collective bargaining. Our Code of Ethics is available on our internal document control site and our intranet, and is available in seven languages. We distribute our Code of Ethics to our independent contractors, and we have made it a contractual obligation for independent contractors to comply with the Code of Ethics. We require suppliers to sign a "compliance with laws" provision into our purchasing agreements, which provision obligates such parties to, among other things, comply with NSF's Code of Ethics, and the anti- modern slavery and anti-trafficking provisions therein. We have posted our Code of Ethics to our main external websites. We are currently working to incorporate modern slavery into our Human Resources and purchasing policies and practices.
Assessment of Modern Slavery Risk Within Our Supply Chain; Effectiveness And KPIs
Due to the impact of COVID-19, NSF’s was not able to complete the modern slavery risk-mapping activity we had planned for 2020. We adapted our activities to focus on the safety of our workforce, including our suppliers and contractors, including adopting COVID response plans and safety measures for all workers, including contractors. We are committed to performing supply chain risk mapping in 2021, and to using such risk mapping to more specifically identify—and minimise—actual risks. We will work with our purchasing, finance, and Human Resources departments to perform our risk mapping, and to develop effectiveness measures and KPIs.
Due Diligence Processes
NSF operates an independent, third-party whistleblowing hotline, which is intended primarily for our employees but is also available to any person who works within our supply chain, as well as to NSF clients, other external stakeholders, and any member of the public, all of whom can access the hotline through our Code of Ethics, which is posted on our main external websites. The hotline can be used to report any ethical, integrity, or compliance issue. All reports received through our hotline are fully investigated by our Ethics Committee, which includes our CFO, our CHRO, and our CLO. The Ethics Committee reports regularly to our CEO and annually to the Audit Committee of the Board of Directors.
All employees, as well as our Board of Directors (who approved the Code of Ethics), are required to complete Code of Ethics training annually. The Code expressly states that any violation of the Code, and any failure to report a suspected violation, may result in discipline up to and including termination. Training on the Code of Ethics covers modern slavery and trafficking specifically, and employees are directed to report any suspected incident of modern slavery through our independent hotline. Our annual ethics has continued during the pandemic.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes NSF's slavery and human trafficking statement for the financial year ending December 31, 2020. This statement is approved by the Board of Directors of NSF International and is signed on behalf of the Board of Directors by Kevan Lawlor, President and Chief Executive Officer.
Kevan P. Lawlor
President & Chief Executive Officer
Updated: February 15, 2021