Supply Chain Transparency

Suntory Global Spirits Inc. (“Suntory Global Spirits”) is pleased to provide the following statement under the California Transparency in Supply Chains Act of 2010 and United Kingdom Modern Slavery Act of 2015.  This statement sets forth the steps that Suntory Global Spirits has taken and is continuing to take to ensure that human rights abuses and modern slavery are not taking place within our operations or our supply chains.

Introduction

As a responsible corporate citizen committed to doing business the right way, Suntory Global Spirits seeks to ensure that quality and safety standards are maintained by well-treated, fairly compensated workers in accordance with all applicable laws.  Accordingly, Suntory Global Spirits has established robust policies, processes, and procedures to promote respect for human rights and to prevent modern slavery practices.

Suntory Global Spirits and its employees respect human rights, workplace safety and protection of the environment in every community where Suntory Global Spirits operates.  Suntory Global Spirits expects the same of our Company’s suppliers and contractors so that we demonstrate our leadership within the business community together.  Suntory Global Spirits does not allow the use of forced, bonded or involuntary prison labor. 

Our Business

Suntory Global Spirits Inc. is a wholly owned subsidiary of Suntory Holdings Limited.   Suntory Global Spirits is a global business headquartered in Chicago, with more than 5,000 employees.  Suntory Global Spirits together with our affiliates and partners produce and distribute premium spirits including bourbon, whiskey, tequila, cognac, vodka, gin, rum, cordials, liqueurs, and ready-to-drink cocktails under various brands, including Jim Beam, Maker’s Mark and Courvoisier.  

Suntory Global Spirits has facilities around the world.  Most of the commercial offices are located in major metropolitan areas, while our operating units are located in North America (USA, Mexico, Canada), Asia (Japan & India), and Europe (UK, Spain, France, Ireland).  

Relevant Policies

Suntory Global Spirits has policies, procedures, and controls in place to prevent and reduce the risk of modern slavery practices and to promote respect for human rights.  The primary policies include:

• Suntory Global Spirits Global Citizenship Policy
• Suntory Global Spirits Code of Conduct and Ethics
• Suntory Global Spirits Supplier Code of Conduct and Ethics 
 

The Global Citizenship Policy provides guidelines to ensure that Suntory Global Spirits and its employees respect human rights, workplace safety and protection of the environment in every community where Suntory Global Spirits is located and expects the same of Suntory Global Spirits suppliers and contractors.  Global Citizenship Policy elements include:

• Working Conditions / Health & Safety
• Child Labor
• Forced Labor
• Discrimination
• Working Hours
• Wages & Benefits
• Environmental
• Management Systems
• Contractors & Suppliers
 

Suntory Global Spirits suppliers and contractors are contractually obligated to comply with the Suntory Global Spirits policies and all applicable laws, including laws related to modern slavery and human trafficking.  Suntory Global Spirits periodically evaluates select suppliers and contractors on their ability to demonstrate evidence of substantial conformance with the Suntory Global Spirits policies, subject to local rules.  Suntory Global Spirits engages and consults with third parties to assist in these evaluations as the circumstances dictate. In addition, Suntory Global Spirits maintains appropriate evidence that the Suntory Global Spirits Policies are substantially being met by suppliers and contractors that have been evaluated, subject to local rules. This evidence may include certification forms, written questionnaires, inspections or other appropriate documentation. 

Suntory Global Spirits employees who have direct responsibility for supply chain management receive training in all aspects of supply chain risk mitigation, which is intended to identify, among other things, circumstances that suggest a high risk of noncompliance with Suntory Global Spirits policies and applicable laws.  Any concerns relating to potential noncompliance to our policies are investigated promptly.  Suppliers that fail to meet Suntory Global Spirits expectations will be terminated. In addition, employees who violate the policies are subject to discipline up to and including termination.

Governance

The Suntory Global Spirits Global Citizenship Committee provides Global Citizenship Policy oversight and governance.  Members of the Suntory Global Spirits Global Citizenship Committee include representatives from sustainability, legal, compliance, human resources, supply chain and communications.  This Committee meets on a routine basis throughout the year to review status of open action items and recommend additional actions (as needed) to ensure conformance to the Global Citizenship Policy.

The Suntory Global Spirits Global Citizenship Committee reports to the Suntory Global Spirits Corporate Responsibility Committee of the Board of Directors.

Our Supply Chain and Managing Risks

It is important to Suntory Global Spirits that we understand our supply chain and operations and properly mitigate risks related to human rights issues and modern slavery.  Suntory Global Spirits is involved in the procurement of ingredients, containers, labels, closures, and cases, as well as contracted services related to marketing, co-manufacturing, transportation, and logistics.  Suntory Global Spirits sources materials from various regions around the world and has a range of relationships with our suppliers and business partners depending on the risk profile and spend.  

In 2021, Suntory Global Spirits, in partnership with a risk management consultant, conducted an evaluation of its supply chain and operations to determine the potential for it to cause, contribute to, or be directly linked to modern slavery and human rights risks.  The framework for this evaluation was based on the United Nations Guiding Principles on Business and Human Rights (UNGPs).  

This evaluation indicated that potential risk categories for Suntory Global Spirits based on its operations are as follows:  Child Labor, Forced Labor, Working Hours, Fair Wages & Welfare, Discrimination, Harassment, Freedom of Association and Right to Collective Bargaining, Access to Remedy, Health, & Safety.  The potential risk categories were separated by risk level (low, medium and high) and we developed an action plan on a risk adjusted basis to address the risks.   

To help prevent risks related to modern slavery and human rights we have taken the following key actions:

• In 2020, Suntory Global Spirits joined the Supplier Ethical Data Exchange (Sedex) and started requiring that suppliers making up 80% of our direct spend become members of Sedex.  Since that time, Suntory Global Spirits has been engaging our suppliers to share information about the actions taken to prevent human rights and modern slavery risks.  This engagement includes the use of the Sedex Supplier Audit Questions (SAQ*) and the 4-Pillar Sedex Member Ethical Trade Audits (SMETA*) to evaluate the potential social risks in the supply chain by focusing on child labor, forced labor and other human rights issues as well as considerations toward the work environment and occupational safety.  This engagement also includes the implementation of action plans to promote corrective actions, when needed.
• Suntory Global Spirits will also began using the Sedex platform to further evaluate our key manufacturing locations, starting with our manufacturing locations based in Mexico and India.  These evaluations will build on the 3rd party social compliance audits previously conducted by Bureau Veritas for co-manufacturers and agricultural operations (agave) in Mexico & India.
• Suntory Global Spirits created two new Supplier Sustainability Manager roles in 2021 to continue to enhance our work in this area.  One position is based in Chicago and the other position is based in Madrid.
• Suntory Global Spirits updated the global citizenship process to identify when and how to use Sedex, SAQs and SMETAs.
• Suntory Global Spirits transitioned 3rd Party Audits to SMETA format allowing us to do a deeper dive into key areas, including around environment and business ethics.

Assessing the Effectivenss of Actions Taken

Suntory Global Spirits considers several key performance indicators in the assessment of the effectiveness of actions taken to mitigate modern slavery and human trafficking risks, including % of suppliers that are Sedex members along with number and type of risk findings and status of corrective action plans. 

As part of our commitment to tackling modern slavery and human trafficking, we will continue to look for ways to improve upon our existing policies, procedures, ways of working and in promoting awareness with our employees and our suppliers. We will continue to expect that our suppliers and our partners share our commitment to tackling modern slavery and human rights issues.

Other Information

Suntory Global Spirits is committed to continual improvement.  Suntory Global Spirits will continue to assess the potential risks in our supply chain and increase the awareness across key stakeholders in our business to ensure that our policies, processes, and procedures are understood and being implemented.  Suntory Global Spirits will monitor and report our progress annually.

Anyone interested in additional information may contact Suntory Global Spirits directly. 

This disclosure statement was approved by the Board of Directors of Suntory Global Spirits on April 19, 2022 as applicable to Suntory Global Spirits and its subsidiaries during fiscal year 2021.