Introduction 

This Global Modern Slavery Statement 2025 (this “Statement”) is made by Otter Products, LLC, on behalf of itself and its affiliates and subsidiaries, including, but not limited to, Otter Products EMEA Unlimited Company and Otter Products UK Limited (collectively, “Otter”). Otter is committed to improving its processes to prevent all forms of modern slavery, including, but not limited to, human trafficking, forced labor, debt bondage, and child labor (collectively, “Modern Slavery”), within its business operations and supply chains. This Statement outlines Otter’s approach and actions in fulfilling this commitment.

Organizational Structure and Operations

Otter is comprised of a global group of companies in the consumer electronics sector that design, source, package, and distribute (amongst other things) accessories for mobile devices. With operations spanning across North America, Europe, Middle East, Africa and Asia, Otter has established itself as a global innovator of premium protective products for smartphones and tablets. For more information, please visit otterproducts.com.

Our Supply Chains

Otter utilizes a global supply chain and omnichannel distribution network to deliver its products.

Modern Slavery Governance

Otter is committed to building a supply chain free from Modern Slavery. Otter has robust policies in place that seek to prevent and condemn Modern Slavery in its business and supply chains including the following:

1. Currently, Otter adheres to the Responsible Business Alliance Code of Conduct (the “RBA Code of Conduct”). The RBA Code of Conduct mandates that Otter’s Tier 1 suppliers do not engage in or support Modern Slavery. Additionally, the RBA Code of Conduct requires suppliers to maintain terms of employment that comply with local laws, ensuring human rights, decency, and appropriate labor standards. These standards encompass labor, health, safety, environmental, ethics, and management requirements. By the end of 2024, Otter plans to transition to the Ethical Trading Initiative Base Code (the “ETI Code of Conduct”) or a similar set of rigorous standards. The ETI Code of Conduct, based on the conventions of the International Labour Organisation, outlines globally accepted labor standards to ensure ethical working conditions within supply chains. It covers nine key areas, including freely chosen employment, freedom of association, safe working conditions, prohibition of child labor, living wages, reasonable working hours, non-discrimination, regular employment, and prohibition of harsh treatment. This transition underscores Otter’s commitment to eradicating Modern Slavery and promoting a responsible and equitable work environment. Throughout the remainder of this Statement, the term “Code of Conduct” will be used interchangeably to refer to the then-current code of conduct, whether it is the RBA Code of Conduct or the ETI Code of Conduct.
2. Otter’s subject matter experts oversee supplier compliance through regular third-party, audits to ensure adherence to Otter’s requirements.
3. Otter condemns all forms of Modern Slavery.
4. Otter mandates that all individuals within its own organization and within its suppliers’ organizations be treated with respect and dignity, free from discrimination or harassment, and provided with a safe working environment. Otter provides resources to report any violations of its policies. Additionally, Otter offers training to its employees to ensure they understand how to maintain a workplace devoid of discrimination and harassment. These measures exemplify Otter's dedication to fostering a responsible and ethical work environment throughout its operations and supply chains.
5. Otter’s safety policies affirm that the health and safety of our people is one of our top priorities and reinforces our commitment to provide a safe workplace where everyone can do their best work. Otter expects its business partners to provide a safe workplace compliant with all local health and safety laws and to implement best practices in reducing workplace accidents and injuries.

Responsible Minerals Sourcing

Otter recognizes conflict minerals are often correlated with instances of Modern Slavery. Otter is dedicated to upholding ethical principles and social responsibility, aligning with laws that combat unethical practices in conflict affected and high-risk areas, including the Democratic Republic of the Congo. Otter strives to comply with conflict mineral regulations and collaborate with our suppliers to responsibly source materials and components. Otter demands transparency and responsible sourcing practices from our suppliers, expecting them to investigate the origin and chain of custody of conflict minerals, disclose due diligence information upon request, and procure minerals from conflict-free sources that do not contribute to human rights abuses globally.

Due Diligence Processes for Slavery and Human Trafficking

Otter’s efforts to manage its supply chain relationships responsibly include the following actions:

1. Verification of Product Supply Chains. Otter strives to establish close relationships with its suppliers and requires that they comply with all aspects of the Code of Conduct including those aspects that relate to Modern Slavery.
2. Supplier Audits. Otter reserves the right to verify supplier compliance with company standards and the Code of Conduct. Otter utilizes independent third-party auditors to perform announced supplier audits and verify supplier compliance. If Otter becomes aware of any actions or conditions not in compliance with its company standards and/or the Code of Conduct, Otter reserves the right to demand corrective measures which may include terminating the supplier’s contract.

3. Certification Requirements for Direct Suppliers. Otter requires its Tier 1 suppliers to certify that materials incorporated into the products comply with the laws regarding Modern Slavery of the country or countries in which they are doing business. Otter presents the Code of Conduct as a total supply chain initiative and requires suppliers to comply with laws regarding Modern Slavery. Otter also requires Tier 1 suppliers to monitor the performance of their next tier suppliers against the requirements of the Code of Conduct.

   As part of the requirements of the Code of Conduct and specialized labor standards, suppliers are required to develop appropriate management systems, which include policies, procedures, and associated documentation, to adhere to the requirements and any applicable laws and regulations, including those prohibiting Modern Slavery. Otter confirms the existence and maintenance of those management systems through our supplier audit program.

4. Internal Accountability Standards and Procedures. Otter requires its employees to comply with company policies, including, but not limited to, policies prohibiting the use of Modern Slavery in its operations. Otter provides channels to report concerns about any potential violation of law or company policy including those related to Modern Slavery. Otter promptly investigates any such reports and takes all necessary corrective actions.
5. Training. Individuals who have direct responsibility for supply chain management are required to undergo mandatory training. This training provides comprehensive information on all company policies, practices, and procedures designed to identify and respond to issues related to Modern Slavery in the supply chain as well as to mitigate risks within the supply chain of products.

Further Steps

Otter recognizes that identifying and mitigating the risks of Modern Slavery requires on-going commitment and continual improvement. We will therefore continue working on our efforts to identify, assess, and address Modern Slavery risks within our operations and supply chains. These efforts include:

1. Continuing to raise awareness by providing training to our employees and members of our supply chain.
2. Conducting investigations of any non-compliance and taking prompt action as appropriate.
3. Monitoring the effectiveness of our policies and procedures.
4. Administering the Modern Slavery self-assessment questionnaire to a targeted and extended group of suppliers through the new platform for supplier due diligence.
5. Continuing to monitor global regulations to combat Modern Slavery.

Approval

The Board of Directors of Otter Products, LLC has formally approved this Statement, applying to both Otter Products, LLC and its affiliated entities and subsidiaries.

Approval for this Statement:

OTTER PRODUCTS, LLC

Trey Northrup, Chief Executive Officer

OTTER PRODUCTS, EMEA UNLIMITED
OTTER PRODUCTS, UK LIMITED

Trey Northrup, Director