July 2015

The Executive Management of Spectrum Brands, Inc. is committed to the principles of Equal Employment Opportunity and Affirmative Action as set forth in Spectrum Brands’ policy.

It is the responsibility of all managers and supervisors to ensure that all personnel actions, including recruiting, employment, work assignments, advancement opportunities, promotions, training, compensation, benefits, leaves of absence, educational refunds, social and recreational programs, etc. are administered in accordance with Spectrum Brands’ Equal Employment Opportunity Policy and Affirmative Action Plans and without regard to race, ethnicity, color, religion, national origin, gender, disability, age, citizenship or veteran status.

In support of our policy, Spectrum Brands has developed affirmative action plans and procedures for minorities and women, for individuals with disabilities, and special disabled veterans and veterans of the Vietnam Era. The Equal Opportunity Officer for Spectrum Brands is Stacey Neu, Sr Vice President, Global Human Resources. She is responsible for coordinating and monitoring the effectiveness of the Equal Employment Opportunity and Affirmative Action Programs. These plans are available for review during normal business hours in local Human Resources departments.

A fundamental element of Spectrum Brands’ policy is to ensure that all employees work together in an atmosphere fostering mutual respect and promoting a harmonious, productive workplace free of harassment, intimidation or any form of discrimination based on race, ethnicity, color, religion, national origin, gender, disability, age, citizenship or veteran status. All employees are encouraged to bring any question or concern related to this matter to their immediate supervisor, local manager or Human Resources representative.

Any employee filing a complaint can expect Spectrum Brands to conduct a complete, confidential investigation and to be informed of the results. Spectrum Brands will not permit or tolerate any form of retaliation against an employee filing a complaint. If the investigation reveals reasonable evidence that Spectrum Brands’ equal employment opportunity Policy or Affirmative action Plans have been violated, appropriate action to eliminate future violations will be taken.

All Spectrum Brands employees are expected to support our Equal Employment Opportunity Policy and Affirmative Action Programs both to ensure legal compliance and to provide a work environment consistent with Spectrum Brands’ values.

Andreas Rouvé, CEO