Skip to content

ITW Human Rights and Modern Slavery Statement

This Statement relates to our fiscal year ended December 31, 2025. It describes the activities of Illinois Tool Works Inc. and its consolidated subsidiaries (the “Company,” “ITW,” “we,” “us” and “our”) to promote respect for human rights, including the elimination of forced labor and human trafficking (collectively referred to herein as “modern slavery”) and child labor from our business and our supply chains, and to promote decent working conditions.

We have prepared this Statement to comply with the California Transparency in Supply Chains Act, the UK Modern Slavery Act, the Australian Commonwealth Modern Slavery Act, the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, and the Norwegian Transparency Act (collectively, the “Acts”). However, not all entities that are part of the Company are subject to the Acts individually or collectively. To the extent applicable, the signature pages to this Statement include additional disclosures specific to the entities required to prepare a statement under one or more of the Acts.

Our Business and Supply Chain

The Company, headquartered in Glenview, Illinois, USA and publicly traded on the New York Stock Exchange, is a decentralized global manufacturer of a diversified range of industrial products and equipment employing approximately 43,000 people at 88 divisions in 49 countries.

ITW’s operations are organized and managed based on similar product offerings and end markets and are reported to senior management as the following seven segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. The Company owns and operates over 400 plants and facilities which in turn source from thousands of suppliers located in over 80 countries. ITW divisions range from OEMs to Tier 1, 2, 3 and potentially Tier 4 suppliers depending on the market served.

Where practicable, we seek to maintain long-term relationships with local suppliers to help us source responsibly and reduce the risk of sourcing from suppliers that do not meet our standards. In 2025, approximately 90 percent of all global supplier spend was with suppliers who are located in an area that aligns with ITW’s strategy to buy materials from suppliers within regions where we manufacture and sell products.

Our Policies and Approach to Human Rights

The ITW Culture is one of the key drivers of our enterprise strategy and encompasses our Core Values of Integrity, Respect, Trust, Shared Risk and Simplicity. We integrate into our Core Values the principles of the United Nations Global Compact, Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. Our Core Values, communicated throughout the Company, call for the highest ethical standards in all interactions with all stakeholders.

Our Core Values, ITW Code of Conduct, Human Rights Policy, Supplier Code of Conduct, Supplier Expectations, Responsible Materials Policy and this Statement together provide the over-arching compliance framework relating to human rights and decent working conditions, across our entire enterprise.

Codes of Conduct

The ITW Code of Conduct mandates compliance with human rights requirements around the globe, including environmental, health and safety laws that protect the well-being of employees and promote decent working conditions, and laws against slavery, human trafficking and child labor. The ITW Code of Conduct applies to all our colleagues, directors, businesses and subsidiaries around the world.

ITW’s Supplier Code of Conduct holds our suppliers accountable to the same standards of conduct set forth in the ITW Code of Conduct. The Supplier Code of Conduct requires our suppliers to treat all workers with dignity and respect and specifically prohibits our suppliers from employing workers that are younger than 15 or knowingly sourcing from suppliers associated with human trafficking. It further prohibits unlawful discrimination and any form of inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse. The

Supplier Code of Conduct also requires our suppliers to make reasonable efforts to ensure that their suppliers comply with our policies. We expect our suppliers to comply with the Supplier Code of Conduct, and we do not knowingly do business with suppliers who violate human rights or health and safety laws. Suppliers are required to establish and maintain a process for ensuring compliance with the ITW Supplier Code of Conduct. This includes communicating the requirements of the code to all employees, affiliates, distributors, subcontractors, agents and other representatives of the supplier who provide products or services to ITW or to ITW’s customers on behalf of ITW. Any violation of the Supplier Code of Conduct may result in immediate termination of the supplier’s relationship with ITW.

We have also published Supplier Expectations which, among other things, set forth ITW’s expectation that suppliers comply with all applicable laws and regulations, including laws against slavery, human trafficking and child labor and other laws pertaining to human rights.

Our Human Rights Policy sets forth ITW’s commitment to human rights in the workplace. Among other things, this includes providing a workplace that protects employee well-being and safety and complies with all applicable laws, including laws against modern slavery and child labor.

Risk Areas in our Operations and Supply Chain

We believe that the risk of adverse human rights impacts, material violations of working conditions and modern slavery and child labor in our own businesses are low given the nature of our businesses and workforce coupled with our internal policies and procedures and strong Core Values (as described in this Statement). Information is provided below regarding the risk of adverse human rights impacts that we have identified in our supply chain.

Unsafe Working Conditions. Our Enterprise Safety Strategy and Safety Policy are based on the following core principles: goal of zero accidents; shared ownership for safety (business and individual); proactive approach focused on accident prevention; continuous improvement philosophy; and compliance with applicable national, regional and local health and safety laws and regulations. Since the initiation of our current Enterprise Safety Strategy in 2016, ITW’s total recordable incident rate and lost time incident rate are down approximately 50%.

Modern Slavery. We recognize that modern slavery is a risk in manufacturing supply chains. The expansive nature of our materials supply chain requires us to conduct business with a variety of suppliers, across a variety of jurisdictions, some of which may be considered high-risk for modern slavery. A modern slavery risk in our supply chain is forced labor that could occur without our knowledge in violation of our policies. While we believe that our existing policies and procedures are effective in mitigating this risk at our direct suppliers, forced labor could take place in upper tiers of the supply chain from which we may be several or more levels removed. Under our Supplier Code of Conduct, suppliers are prohibited from sourcing products or utilizing services from entities associated with modern slavery.

We recognize there are potential risks associated with the production of certain commodities and with the use of temporary labor in our supply chains. In line with UN Guiding Principles 17 and 24, we evaluate modern slavery and child labor risks relating to our purchased products using a System which screens against the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor and other resources to help identify high-risk suppliers. ITW also conducts internal research relating to modern slavery risk using other U.S. government and non-governmental organization resources, including monitoring of Withhold Release Orders (“WROs”) issued by U.S. Customs and Border Protection, if and when received. In addition, we host an internal website and training for our businesses which contains pertinent global customs information. ITW also conducts supplier outreach in connection with our conflict minerals country of origin inquiries, participates in relevant industry groups and engages with other relevant stakeholders.

Steps to Mitigate Risks relating to Human Rights and Working Conditions

We engage in the activities discussed below to mitigate risks relating to adverse human rights impacts and ensure decent working conditions in our enterprise and in our supply chains. ITW’s processes are intended to align with the OECD Guidelines for Multinational Enterprises.

Consistent with our decentralized operating structure, our individual businesses are responsible for assessing and addressing human rights risks, including those related to modern slavery and child labor, in their own businesses and in their supply chains, based on their particular business and
risk profile. They also are responsible for managing their own working conditions. However, ITW’s corporate compliance team administers training for our colleagues around the world, as appropriate, including training on identifying and avoiding harassment in the workplace and mitigating modern slavery risk. Additionally, our business units are expected to operate in accordance with our Core Values, and all other ITW policies and procedures as described in this Statement.

Supplier and Risk Assessments; Supply Chain Verification. Our businesses evaluate prospective suppliers during supplier selection and periodically thereafter based on financial, legal and sanctions risk. The evaluation may include steps to assess human rights-related risks, such as a supplier questionnaire requesting information about the supplier’s manufacturing processes, quality control, delivery, technology, and other information relative to overall management of the supplier company. In addition, ITW screens all suppliers through a System that measures inherent risk, site risk and management controls relating to governance, environmental and social factors. Results are analyzed and continuous improvement is being applied where practicable. System access is available to all ITW businesses.

We continue to consider how best to support and enhance our framework and processes to further identify and respond to human rights-related risks in our supply chains and assess the effectiveness of our program.

Audits. Prior to placing business with a supplier, an onsite supplier visit may be made by ITW personnel for purposes of confirming the supplier’s overall capabilities related to manufacturing, quality, delivery, and technology, and assessing overall supplier risk. Additionally, after business has commenced with a supplier, onsite supplier visits may be performed periodically by ITW personnel. Although the specific purpose of onsite visits is not typically to assess human rightsrelated risks, non-compliance with ITW’s Supplier Code of Conduct, which sets our expectations for respecting human rights and ensuring decent working conditions, may be identified during the overall supplier assessment. We believe that onsite supplier visits by ITW personnel discourage abusive working conditions and human rights violations. If a violation of human rights were to be identified, ITW would take appropriate steps to remediate the situation.

Contract Terms. Our Standard Terms and Conditions of Purchase provide that direct suppliers must comply with all applicable laws relating to modern slavery and child labor and require direct suppliers to comply with our Supplier Code of Conduct.

Supplier Certifications. Based on our supplier risk evaluation, we ask suppliers deemed to be high-risk to review and sign our Supplier Code of Conduct. We also require our higher-volume suppliers who sell us product containing tin, tantalum, tungsten and/or gold to certify as to the origin of the minerals to determine whether such minerals or materials may be supporting conflict. In addition, some ITW divisions collect and report information with respect to other regulated and non-regulated minerals upon customer request. This certification process helps to identify and mitigate the risk of modern slavery, child labor and other violations of human rights.

Grievance Mechanisms. All ITW colleagues are encouraged to share any ethics or compliance concerns through multiple channels, including to their local management teams, the Legal Department, Internal Audit or the ITW Confidential Helpline. ITW partners with a third-party supplier that provides a web- and telephone-based confidential reporting system in all countries in which ITW does business. Web-based reporting is offered in 16 languages, and telephone-based reporting is offered in more than 200 languages. The ITW Confidential Helpline is also available to suppliers and other external stakeholders. ITW has a no-retaliation policy for good-faith reporting. All reports are investigated promptly and appropriately, and regular updates are provided to the Audit Committee of the Board of Directors.

Internal Accountability and Training

Compliance Team. Employees at our decentralized business units are involved in compliance efforts and are responsible for mitigating risks relating to human rights and working conditions in our enterprise and in our supply chains. At the corporate level, we have a cross-functional Responsible Sourcing Committee headed by ITW’s Vice President, Strategic Sourcing and EHSS, who reports to ITW’s CFO. The Committee includes Strategic Sourcing, Environmental, Legal, Internal Audit, IT, Trade Compliance, Corporate Communications and other selected personnel who meet to discuss responsible sourcing practices, including those related to modern slavery.

Training and Knowledge Management. Our sourcing personnel are trained in the requirement to act ethically and in accordance with the ITW Code of Conduct. In addition, we require our global sourcing employees, global employees who work with suppliers and customers on conflict minerals requests, and our Responsible Sourcing Committee members to undergo specific modern slavery training. This training is intended to generate awareness of modern slavery among our sourcing professionals and to enable them to address identified issues within our product supply chains. We believe our sourcing professionals who have received training regarding modern slavery indicators are better able to identify and mitigate these risks at their respective suppliers and track employees’ participation in the training. We also host an internal website that contains this training and additional materials on this topic.

Employee Certifications. Employees are required to annually certify compliance with the ITW Code of Conduct, which includes a commitment to compliance with human rights-related laws, including those prohibiting modern slavery and child labor.

Assessing the Effectiveness of Our Actions. We utilize information that we receive from audits and grievance mechanisms to understand the performance of ITW’s work to respect and promote human rights and decent working conditions.

Additional Corporate Social Responsibility Efforts

For more information on our efforts and our achievements relating to corporate social responsibility, see our Sustainability Report, which is available at itw.com/sustainability.

Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act Approval

ITW Canada Inc. is required to prepare a report pursuant to the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Canadian Act”). ITW Canada Inc. is a corporation that was wholly owned by ITW Participations S.à r.l., a Luxembourg limited liability company, through December 31, 2025. Illinois Tool Works Inc. (“ITW”), a Delaware corporation, indirectly owned 100% of ITW Participations S.à r.l.’s ownership interests as of December 31, 2025. ITW Canada Inc. is comprised of various autonomous business units (divisions) that operate as manufacturers and/or distributors in the construction, specialty products, food equipment, polymers & fluids, and welding industries. The operating divisions of ITW Canada Inc. are ITW Laminations, Hobart Food Equipment Group (sales and service), Owen Sound (Ware washers), ITW Construction Products, Permatex Canada, and Tregaskiss. Combined, these divisions employ approximately 550 employees in Canada.

The supply chain of ITW, including ITW Canada Inc.’s supply chain, is discussed earlier in this Statement. The policies and procedures used by ITW, to assess, mitigate and manage the risks of forced and child labour, as described earlier in this Statement, are applicable to ITW Canada Inc.

Solely for purposes of compliance with the Canadian Act, this Statement was approved pursuant to subparagraph 11(4)(b)(i) of the Canadian Act by the Board of Directors of ITW Canada Inc.

In accordance with the requirements of the Canadian Act, and in particular section 11 thereof, I, in the capacity of Director, attest that I have reviewed the information contained in this Statement on behalf of the governing body of ITW Canada Inc. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this Statement is true, accurate and complete in all material respects for the purposes of the Canadian Act, for the reporting year ended December 31, 2025.

 

Stephen Tabb, Director
May 28, 2026

Back To Top
Search