Otter Products Global Modern Slavery Statement 2026

Introduction

This Global Modern Slavery Statement 2026 (“Statement”) is made by Otter Products, LLC, on behalf of itself and its affiliates and subsidiaries, including Otter Products EMEA Unlimited Company and Otter Products UK Limited (collectively, “Otter”). This Statement applies to all Otter entities, as listed on our website (otterproducts.com). 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 globally, 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. Key sourcing regions include Asia and South America, with supplier tiers ranging from direct (Tier 1) to indirect (Tier 2 and beyond). Product and material categories with elevated Modern Slavery risks are regularly mapped and assessed.

Legal and Regulatory Coverage

Otter complies with all applicable Modern Slavery laws and regulations, including the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and the California Transparency in Supply Chains Act. Supplier contracts require compliance with these and other relevant laws.

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. Otter adheres to the Ethical Trading Initiative Code of Conduct (“ETI Code of Conduct”), and has transitioned to the SEDEX platform, and use of SMETA audit methodology for supplier oversight. The ETI Code applies to Tier 1 suppliers, with a phased plan to extend coverage to indirect suppliers by the end of 2026.
2. Supplier contracts mandate terms of employment that comply with local laws, ensuring human rights, decency, and appropriate labor standards. The ETI Code covers nine key areas: 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.
3. Subject matter experts oversee supplier compliance through regular third-party audits. Audits are conducted annually. Suppliers identified as having greater operational or compliance impact receive both scheduled and unannounced audits, while those with lower impact are audited less frequently.
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.
5. Otter provides resources to report any violations of its policies, including a confidential hotline, dedicated email, and whistleblowing platform accessible to all employees and supply chain workers.
6. Otter requires training for its employees and supply chain managers to ensure they understand how to maintain a workplace devoid of discrimination and harassment.
7. Tier 1 suppliers are required to provide training to their staff, and Otter offers resources for supplier training.
8. Otter’s safety policies affirm that the health and safety of our people is a top priority. We expect suppliers 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 that 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 collaborates with suppliers to responsibly source materials and components. Suppliers are expected 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 process to manage its supply chain relationships responsibly includes:

1. Verification of Product Supply Chains. Otter establishes close relationships with suppliers and requires compliance with all aspects of the Code of Conduct, including those related to Modern Slavery.
2. Supplier Audits. Otter reserves the right to verify supplier compliance with company standards and the Code of Conduct. Independent third-party auditors perform both announced and unannounced audits. Audit frequency is generally annual, with increased frequency for suppliers whose operations or compliance impact warrants closer oversight. In certain cases, audits may occur biennially or at other intervals based on risk assessment. Instances of non-compliance may trigger corrective actions, which can include contract termination. Non-compliance triggers corrective measures, which may include contract termination.
3. Certification Requirements for Direct Suppliers. Tier 1 suppliers must certify that materials incorporated into products comply with Modern Slavery laws of the countries in which they operate. Otter presents the Code of Conduct as a total supply chain initiative and requires suppliers to monitor the performance of their next tier suppliers against the Code of Conduct.
4. Management Systems. Suppliers must develop appropriate management systems—including policies, procedures, and documentation—to adhere to requirements and applicable laws, including those prohibiting Modern Slavery. Otter confirms the existence and maintenance of these systems through its audit program.
5. Internal Accountability Standards and Procedures. Otter requires employees to comply with company policies, including those prohibiting Modern Slavery. Channels to report concerns include a confidential hotline, dedicated email, and whistleblowing platform. Otter promptly investigates reports and takes all necessary corrective actions.
6. Grievance Mechanisms and Remediation. Reporting channels are available to all stakeholders, including external parties. Remediation steps for identified Modern Slavery cases include immediate investigation, corrective action, and, where necessary, termination of supplier contracts.

Risk Assessment

Otter conducts formal risk assessments annually, mapping high-risk suppliers, countries, and product categories using SEDEX/SMETA tools. The risk assessment methodology is reviewed regularly to ensure a risk-based approach.

Training and Capacity Building

All employees and supply chain managers receive annual Modern Slavery training. Tier 1 suppliers are required to provide training to their staff, and Otter offers resources for supplier training. Training frequency, scope, and nature are reviewed annually.

KPIs and Effectiveness

Otter actively monitors and discloses key performance indicators to assess the effectiveness of its Modern Slavery compliance program, including the percentage of suppliers audited, the completion rate of corrective actions, the number of reports received and resolved, and training completion rates among employees and supply chain managers.

Further Steps

Otter remains committed to combating Modern Slavery through a multifaceted approach that includes raising awareness by delivering comprehensive training programs to both employees and supply chain partners, conducting thorough investigations into any instances of non-compliance and taking swift corrective action when necessary, and continuously monitoring the effectiveness of its policies and procedures. To strengthen supplier due diligence, Otter administers the Modern Slavery self-assessment questionnaire to a targeted and increasingly extensive group of suppliers using a new digital platform. Otter also keeps abreast of evolving global regulations related to Modern Slavery, ensuring ongoing compliance. In the spirit of transparency and accountability, Otter publicly reports its progress and key performance indicators on its website, demonstrating an unwavering commitment to driving positive change throughout its operations and broader supply chain.

Approval and Public Reporting

This Statement was approved by the Board of Directors of Otter Products, LLC on December 1, 2025, and applies to Otter Products, LLC and its affiliated entities and subsidiaries. This Statement is publicly accessible at otterproducts.com/modernslavery and through other regional websites.

Approval for this Statement:

OTTER PRODUCTS, LLC

Charles Northrup, III, Chief Executive Officer

OTTER PRODUCTS EMEA UNLIMITED COMPANY
OTTER PRODUCTS UK LIMITED

Charles Northrup, III, Director

Contact Information for External Inquiries

For questions or concerns regarding this Statement, please contact:

Email: legal@otterproducts.com
Website: otterproducts.com/modernslavery