Modern Day Slavery Statement
I. INTRODUCTION
The KONG Company LLC (“KONG Company”) and its subsidiaries continually work to prevent
slavery and human trafficking from taking place in our manufacturing supply chains and
operations. This report details the steps that the KONG Company and its subsidiaries take to
reduce and eliminate forced and child labour from their supply chains.
This report fulfills the requirements of the UK’s Modern Slavery Act 2015 (UK MSA). This is the
first report of the KONG Company under Canada’s Fighting Against Force Labour and Child
Labour in Supply Chains Act (“Canadian MSA”).
Reporting entities in the United Kingdom are KONG Company Limited (“KCL”), and reporting
entities in Canada are KONG Company LLC. These entities are collectively referred to as
“KONG” herein. The information included in the statement refers to the financial year 2024.
II. STRUCTURE, ACTIVITIES AND SUPPLY CHAIN
a. Structure and Activities
The KONG Company is an American company headquartered in the state of Colorado that
develops designs and produces lines of dog and cat toys and treats. KONG has been
innovating since 1976 to enrich the lives of pets with the highest quality pet toys and treats. The
KONG product line provides mental and physical stimulation through encouraging play,
appropriate chewing habits, and controlled feeding to help ensure pets are at their happiest and
healthiest at every life stage.
KONG Company is headquartered in Golden, Colorado. Operations span North America (USA)
the United Kingdom and Australia. There are around 200 employees in the USA, 30 in the UK
and EU and 10 in Australia. No employees in Canada at this time.
The KONG Company is proud to be a founding member of the Pet Sustainability Coalition.
For the UK, operations are managed by KCL. KCL is controlled and owned by the KONG
Company. The two company directors are Kathy Decker Frueh and John Nelson who are based
in the USA. The head office for KCL is:
Unit 7 High Post Business Park
Salisbury
SP4 6AT
KCL is a distributor for the UK and Europe. The KONG Company supplies all products, which
are imported from either the USA or China. KCL operates all year round and work UK office
hours mostly Monday to Friday.
In the UK, most of our workers are based in Salisbury. We have a couple of UK sales personnel
and members of staff located in Germany, Greece and Finland.
Our Canadian operations are done through the KONG Company USA. This includes importing,
distributing, and selling our products within Canada.
Further information about our business is available from website online:
https://www.kongcompany.com/
b. Supply Chains
In order to fulfil its activities, KONG Company supplies dog and cat toys and treats. Our
suppliers are globally sourced.
III. COMMITMENT
KONG acknowledges its responsibilities in relation to tackling modern slavery and
commits to complying with the provisions in the UK MSA and the Canadian MSA. KONG
understands that this requires an ongoing review of both its internal practices in relation
to its labour force and, additionally, its supply chains.
KONG does not enter into business with any organization, which knowingly supports or
is found to involve itself in slavery, servitude and forced or compulsory labour. No
labour provided to KONG, in the pursuance of the provision of its own services, is
obtained by means of slavery or human trafficking. KONG strictly adheres to the
minimum standards required in relation to its responsibilities under relevant employment
legislation.
IV. POTENTIAL EXPOSURE / RISK
KONG considers its main exposure to the risk of slavery and human trafficking to exist in
China where they involve the provision of labour in a country where protection against
breaches of human rights may be limited.
In general, KONG considers its exposure to slavery/human trafficking to be relatively
limited. KONG has taken steps to ensure that such practices do not take place in its
business nor the business of any organization that supplies goods and/or services to it.
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, but are not limited to:
• 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.
V. POLICIES & DILIGENCE
KONG 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.
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 operations.
KONG evaluates and addresses risks of modern slavery and human trafficking in business
operations which, among other standards, include that:
• Suppliers must not use forced labour – slave, prison, indentured, bonded, or otherwise.
• 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.
• 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.
KONG carries out due diligence processes in relation to ensuring slavery and/or human
trafficking does not take place in its organization or supply chains, including conducting a review
of the controls of its suppliers.
Most recently, KONG has reviewed the Uyghur Forced Labor Prevention Act (UFLPA)
compliance. In doing so, suppliers certified that their products are not produced, and material is
not sourced from the Xianjiang Uyghur Autonomous Region of China.
Additionally, KONG has reviewed its supplier contracts to include termination powers in the
event that the supplier is, or is suspected, to be involved in modern slavery.
VI. SLAVERY COMPLIANCE OFFICER
The KONG Company and its subsidiaries have a Slavery Compliance Officer, to whom
all concerns regarding modern slavery should be addressed, and who will then
undertake relevant action with regard to the KONG Company’s obligations in this regard.
VII. REMEDIATION
The KONG Company has not identified any incidents of forced or child labour in their supply
chains. As such, they have taken no remediation measures. KONG is committed to taking
appropriate remediation measures and assisting vulnerable persons to the extent they become
aware of any instances of forced or child labour.
VIII. TRAINING
Our factory partners are currently conducting training for their employees. We receive yearly
third party social and ethical audit results (SMETA, BSCI, etc.) as part of our supplier diligence,
policies, and practices. KONG currently is researching training options for applicable
employees, including the Slavery Compliance Officer.
IX. EFFECTIVENESS
KONG’s policies are reviewed annually to ensure that they meet the companies needs
and stakeholder expectations. This includes our policies related to forced and child
labour.
APPROVAL & ATTESTATION
This statement Is made In pursuance of Section 54( 1) of the Modern Slavery Act 2015 and
Canada's Fighting Against Force Labour and Child Labour in Supply Chains Act and will be
reviewed for each financial year.
In accordance with the requirements of the Canadian MSA and the UK MSA, I attest that I have
reviewed the information contained in the report for KONG Company and KLC. I attest that the
report has been approved by the board of directors of the KONG Company and that, based on
my knowledge and having exercised reasonable diligence, the information in the report is true,
accurate and complete in all material respects for the purposes of the Act, for the reporting year
listed.
Signature:
Name: Kathy Decker Frueh
Title: President
Date: May 28, 2025
I have the authority to bind KONG Company LLC