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  4. Ethical Sourcing

Ethical Sourcing

Our suppliers are held to global fundamental principles of human dignity. Our Ethical Sourcing Standards are the foundation of our global supply chain initiative, requiring our direct suppliers to protect the health, safety and human rights of their associates. We will not conduct business with suppliers who do not support the fundamental principles of human dignity and rights of workers to fair and equitable treatment.

Abiding by Ethical Sourcing Standards

Suppliers must meet our standards regarding forced labor, child labor, health and safety in the workplace, fair pay, harassment, diversity and ethics, and environmental policies. We require that our suppliers identify and act swiftly to eliminate any unacceptable conditions or practices in their facilities. We base our supplier requirements on international standards including the United Nations Declaration of Human Rights, the United Nations Convention on the Rights of the Child, and the Conventions of the International Labour Organization, including its Fundamental Principles and Rights at Work.

Verification.?In order to evaluate and address risks of human trafficking and slavery in our supply chains, Ecolab has developed a detailed supplier ethical assessment that our top suppliers must complete in order to verify compliance with Ecolab's ethical sourcing requirements. Ecolab has required our top suppliers in the chemical, packaging, equipment and contract manufacturing categories to complete the assessment, and we continue to expand the number and scope of suppliers required to complete the management practices and specific performance related to protection of employees' human rights and prevention and elimination of trafficking and slavery. Ecolab does not currently conduct on-site audits of suppliers related to trafficking and slavery in supply chains, but is evaluating whether to expand its existing assessment program to ensure compliance with trafficking and slavery standards.

Certification.?Ecolab requires all suppliers to comply with applicable government regulations, as well as with Ecolab policies and procedures. We incorporated a certification requirement to that effect into our supplier ethical assessment in 2012.

Accountability.?Ecolab's employees are held accountable for ensuring we meet our standards regarding slavery and trafficking as expressed in Ecolab's Code of Conduct. The Code of Conduct requires employees and contractors to engage in ethical source selection. It also makes clear that compliance with applicable government regulations and Company policies and procedures is required of all Ecolab suppliers, agents and consultants.

Training.?Ecolab provides training to our supply chain and purchasing employees, as well as to our suppliers, regarding Ecolab's ethical sourcing policies and procedures.

Conflict Minerals

In 2014, we finalized a process for managing conflict minerals (tin, tungsten, tantalum and gold—collectively known as 3TG) in our supply chain and filed our first Conflict Minerals Report for the 2013 reporting year as required by the United States Securities and Exchange Commission (SEC)*. Our conflict minerals management infrastructure established in 2014 includes robust supplier disclosure and procurement management systems. In subsequent years we have implemented a number of process improvements, including enhanced supplier engagement and further refinement of the scope of materials to review. Our scoping work identified the equipment portion of our supply chain as the nearly exclusive source of the potential for conflict minerals and therefore, in the limited cases where we put equipment into commerce, we have established a process to efficiently provide a 3TG disclosure to customers to facilitate their own SEC reporting.

*In response to the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, approved by the United States Securities and Exchange Commission in August 2012.

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Conflict Minerals Policy

Ecolab has developed and adopted an official Conflict Minerals policy outlining our company commitment and expectations for our suppliers.

We are a member of RMI.? For more information about the initiative visit www.responsiblemineralsinitiative.org/.