The Sherwin-Williams Company and its subsidiaries (“Sherwin-Williams” or “we”) value and respect the human rights of all people, including our employees and persons engaged with us, such as suppliers, vendors, subcontractors at all tiers, and their employees (“Suppliers”). We require all employees to support the human rights of others and to abide by this Human Trafficking Policy (“Policy”).

This Policy applies to all countries in which we operate and, where local laws conflict with this Policy, we seek to abide by the applicable laws while honoring the spirit of this Policy. We are committed to working with our Suppliers to ensure that this Policy is respected at all levels of our supply chain.

This Policy prohibits the following activities:

• Engaging in trafficking in persons.
• Procuring commercial sex acts during the performance of their duties.
• Using forced labor.
• Using child labor.
• Using any individual held in slavery or servitude.
• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses.
• Using misleading or fraudulent recruitment practices, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work.
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
• Charging employees recruitment fees.
• Failing to provide, when portions of contracts or subcontracts are performed outside their home country, return transportation or pay for the cost of return transportation upon the end of employment for an employee who is not a citizen of the host country in which the work is taking place and who was brought into that county for the purpose of working on our behalf.
• Providing return transportation or paying the cost of return transportation for an employee that is the victim of trafficking, child labor or slavery and is seeking victim services or legal redress in the country of employment, or providing return transportation or paying the cost of return transportation for an employee that is a witness in an enforcement action related to human trafficking, when the return transportation obstructs victim services, legal redress, or witness activity.
• Providing or arranging housing that fails to meet the host country housing and safety standards.
• Failing to provide an employment contract, recruitment agreement, or similar work document in writing and in a language the employee understands, to the extent such work documents are required by law or contract to be in writing.
• Failing to provide an employment contract, recruitment agreement, or similar work document that, to the extent the work documents are required by law or contract to be in writing, does not include details about the work description, wages, prohibitions on recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.
• Failing to provide an employment contract, recruitment agreement, or similar work document to an employee at least five days prior to the employee relocating if the employee must relocate to perform the work and to the extent the work documents are required by law or contract to be in writing.

We are committed to working with our Suppliers to ensure that human rights are respected at all levels of our supply chain and that no trafficking in persons, forced labor and child labor exists in it.

Our actions to ensure human rights are respected include the following:

• As part of its contracting processes, to negotiate the inclusion of prohibitions against the use of forced, trafficked or child labor or any individual held in slavery of servitude, allow for on-site and other auditing processes and for the termination of contracts for non-compliance.
• Train our key employees involved in procurement activities in this policy to ensure its compliance.

Any violation of the Policy by Suppliers may result in the termination of their contract.