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Modern Day Slavery Statement

KONG Company Code of Conduct statement

1st January, 2019

Modern Day Slavery Statement

KONG Company continually works to prevent slavery and human trafficking from taking place in our manufacturing supply chains and operations, in line with the United Kingdom Modern Slavery Act 2015.

Policies and Controls

KONG Company internally sets out guiding principles and establishes that in performing job duties KONG employees should always act lawfully, ethically, and where appropriate in the best interests of KONG Company.

KONG has set clear standards on the prevention of forced labour in its supply chain required of all manufacturing suppliers, and service providers supporting KONG’s internal operations.

We evaluate and address risks of modern slavery and human trafficking in our business operations which, among other standards, include that:

  • Our suppliers must not use forced labour – slave, prison, indentured, bonded, or otherwise.
  • Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice.
  • Workers shall not be required to pay recruitment, hiring, or other similar fees related to their employment; our suppliers must bear or reimburse to their workers the cost of any such fees. All fees and expenses charged to workers must be disclosed to KONG and communicated to workers in their native language in advance of employment.
  • Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing.
  • Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker.
Due Diligence Processes

KONG assesses manufacturing suppliers and service providers for continued compliance and improvement. Many sites are assessed multiple times a year, including follow-up assessments to address specific findings. Assessments may include:

  • Site inspection of all areas of the site;
  • Confidential worker interviews or surveys conducted without site management present;
  • Review and analysis of site documents or licenses to assess workers’ age, contracts, compensation, working hours, and workplace conditions;
  • Identification of past compliance issues, areas for improvement, and development of a remediation plan.
  • Audit reports and findings are reviewed regularly by senior leadership and corrective action plans are implemented as needed.
Approval for this statement

This statement was approved by the KONG European Board of Directors and covers all activities undertaken by KONG.

Kathy Decker Frueh
KONG Company president signature
President, KONG Company