PRIVACY & COOKIE POLICY

At HOBART UK, we aim to be open about the way our site works to collect user data, and we are committed to safeguarding the privacy of our website visitors.  This policy sets out how we will treat your personal information.

This Privacy Policy describes how your personal information is collected, used, and shared when you visit www.HOBARTUK.com (the “Site”).

PERSONAL INFORMATION WE COLLECT

When you visit our Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. On our Site, we use ‘Usercentrics’ content management platform. To read more about how we use cookies, visit https://www.hobartuk.com/gtc
• For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

HOW DO WE USE YOUR PERSONAL INFORMATION?

When you supply us with personal information on the website, through our online contact form, we use the information that we collect generally to communicate with you and answer any queries you may have. When in line with the preferences you have shared with us, we may also use this data to provide you with information or  advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We may share your Personal Information within the ITW Group of Companies, including HOBART UK, HOBART Service UK and others. For the full list of ITW Companies, please visit: https://www.itw.com/about-itw/business-segments/food-equipment/.

We share your Personal Information with third parties to help us use your Personal Information, as described above. We use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We use Instapage https://instapage.com/ and Arkflux https://www.arkflux.com/ as third-party hosts for some of our website pages. These Instapage and Arkflux pages work as an extension of our website, any Personal Information you provide through these pages will be used in line with our Privacy Policy.

Instapage and Arkflux both collect Device Information in the same way as our website, all detailed above in our Privacy Policy.

On our Site and on Instapage and Arkflux, when you “opt-in” to our marketing communications, data is automatically stored in third party websites: Campaign Monitor https://www.campaignmonitor.com/ and Arkflux https://www.arkflux.com/. These websites are used only to store information and to contact “opted in” customers direct via email campaigns and other marketing campaigns.

Where relevant and where the appropriate consent has been provided, your Personal Information may be shared with Caterlyst www.caterlyst.co.uk. Caterlyst is a third-party website which may send you information about other products and services within the Foodservice industry as a part of carrying out ‘legitimate interests’.

Legitimate interests are outlined in the GDPR regulations as “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)”

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

OPT OUT OF MARKETING COMMUNICATIONS

You can Opt Out of marketing messages at any time by emailing us privacy(at)hobartuk.com. Alternatively, if you click ‘Unsubscribe’ in any marketing email communication we send you, your information will be removed for our marketing database.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. 

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person e.g. in response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes).

YOUR RIGHTS

You have a right to request access to, correct or update the personal data which we hold about you. You also have a right ask us to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us and to transit such personal data to another data controller.

To make a request, please contact us at privacy(at)hobartuk.com or by post to the Data Protection Team, Hobart UK, Southgate Way, Orton Southgate, Peterborough, PE2 6GN.

If you think any information we have about you is incorrect or incomplete, please write to us or email us and we will correct or update any information as soon as possible.

If you are unhappy with our processing of your personal data, you have the right to complain to the Information Commissioner’s Office at any time. Please visit www.ico.org.uk for more information.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

CHANGES

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at customer.service(at)hobartuk.com or by mail using the details provided below:

HOBART UK. Southgate Way, Orton Southgate, Peterborough, PE2 6GN, United Kingdom

HOBART UK respects your personal privacy and is committed to adhering to the applicable privacy and data protection laws and industry guidelines, including GDPR. This cookie notice "Cookie Notice" and our Website Privacy Policy describe how we handle the personal information that you provide to us on this website. This notice applies only to the HOBART UK website portfolio (including but are not limited to www.hobartuk.com www.hobartindependent.com www.hobartpartners.com) and not to any third-party sites that may be accessible from here.

UserCentrics Consent Management

a) General
In order to improve your visit to our website and enable the use of certain functions, we use cookies on various pages. They are small text files that are stored on your end device. Some of the cookies we use are deleted when you finish your browser session, i.e. when you close your browser (so-called session cookies). Other cookies remain on your end device and allow us or our partner companies to recognise your browser the next time you visit the site (persistent cookies). We use cookies to personalise content and advertisements and to analyse visits to our website. We also provide information about your use of our website to our partners for social media, advertisement and analysis purposes. If you click on "More Info" in the cookie popup, you will receive further information about the cookies we use.

b) Consent
By clicking on the consent button on the homepage, you have agreed to the use of cookies. Consent to the use of cookies that are not strictly necessary for the website to run can be withdrawn at any time with effect for the future. To do so, click on the withdrawal button "Decline". However, not accepting cookies may limit the functionality of our website.

c) Control after consent
Apart from that, you can control and/or delete cookies at will if you have agreed to their usage. You can delete all cookies saved on your computer and set most browsers so that storage of cookies is prevented. However, you may then have to manually change some settings each time you visit a site and accept that some functions may be compromised. In addition, please note the following point d).

d) Legal basis
Your consent is the legal basis for the use of cookies. We will use one or more cookies only if you have agreed to the use of cookies in the cookie pop-up that appears when you visit our website. In this case, the legal basis is Art. 6 Paragraph 6 1 a of GDPR. You can withdraw your consent at any time.

Marketing

These technologies are used by advertisers to serve ads that are relevant to your interests

LeadLab

This is a marketing service. This service helps to generate new leads.

Processing company

WiredMinds GmbH, Lindenspürstrasse 32, 70176 Stuttgart, Germany

Data Purposes

This list represents the purposes of the data collection and processing.

Analytics

• Optimization
• Generating leads

Technologies Used

• Cookies
• Web beacons
• Pixel

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• IP address
• Usage data

Legal Basis

In the following the required legal basis for the processing of data is listed.

• Art. 6 para. 1 s. 1 lit. f GDPR
• Location of Processing
• European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes.

Data Recipients

WiredMinds GmbH, Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company:

datenschutzbeauftragter(at)wiredminds.de

Click here to read the Privacy Policy of the data processor https://wiredminds.de/datenschutz-leadlab/

Click here to read the Cookie Policy of the data processor https://wiredminds.de/datenschutz-leadlab/

Google Maps

This is a web mapping service.

Processing company

Google Ireland Limited

Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data Purposes

This list represents the purposes of the data collection and processing.

Displaying Maps

Technologies Used

Cookies

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

Date and time of visit

Location information

IP address

URL

Usage data

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes.

Data Recipients

Google Ireland Limited

Google LLC

Alphabet Inc

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

https://support.google.com/policies/troubleshooter/7575787?hl=en

Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.

United States of America, Singapore, Taiwan, Chile

Click here to read the Privacy Policy of the data processor http://www.google.com/intl/de/policies/privacy/

Click here to opt out from this processor across all domains https://safety.google/privacy/privacy-controls/

Click here to read the Cookie Policy of the data processor https://policies.google.com/technologies/cookies?hl=en

Storage Information

Below you can see the longest potential duration for storage on a device, as set when using the cookie method of storage and if there are any other methods used.

Maximum age of cookie storage: 6 months

Arkflux

This is a service that helps with business growth.

Processing company

Arkflux, Peterborough, Great Britain

Data Purposes

This list represents the purposes of the data collection and processing.

• Optimization
• Functionality
• Marketing

Technologies Used

Cookies

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• IP address
• User agent
• Page visited
• Date and time of visit

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

United Kingdom, European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes

Data Recipients

Arkflux

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

support(at)arkflux.com

Click here to read the Privacy Policy of the data processor https://www.arkflux.com/privacy-policy/

Instapage

This is a service that helps with business growth.

Processing company

Instapage, 118 King St. Ste. 450, San Francisco, CA 94107, United States

Data Purposes

This list represents the purposes of the data collection and processing.

• Optimization
• Functionality
• Marketing

Technologies Used

Cookies

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

Information automatically collected when Cookie Policy is agreed to:

• IP address
• User agent
• Page visited
• Date and time of visit

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

United Kingdom, European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes

Data Recipients

Instapage

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

dpo@instapage.com

Click here to read the Privacy Policy of the data processor https://instapage.com/gdpr

Inxmail

This is an e-mail marketing service.

Processing company

Inxmail GmbH

Wentzingerstraße 17, D-79106 Freiburg, Germany

Data Purposes

This list represents the purposes of the data collection and processing.

• Analytics
• Optimization
• Marketing
• Technologies Used
• Cookies
• Web beacons
• Pixel
• Log Files
• Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

Usage data

• Date and time of visit
• Browser information
• IP address
• E-Mail address

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data is retained as long as necessary to fulfill the purpose(s) for which it was collected.

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

datenschutz(at)inxmail.de , Herr Stefan Fischerkeller

Click here to read the Privacy Policy of the data processor https://www.inxmail.de/datenschutz

Click here to read the Cookie Policy of the data processor https://www.inxmail.de/datenschutz

Functional

These technologies enable us to analyse the use of the website in order to measure and improve performance.

reCAPTCHA

This is a service that checks whether data entered on a site is entered by a human or by an automated program.

Processing company

Google ​Ireland​ Limited

Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data Purposes

This list represents the purposes of the data collection and processing.

• Tracking
• Bot Protection
• Technologies Used
• Cookies

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• Browser language
• Browser plug-ins
• Click path
• Date and time of visit
• IP address
• User behaviour
• Amount of time spent on a page
• User input

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. f GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

Data will be deleted as soon as they are no longer needed for the processing purposes.

Data Recipients

Alphabet Inc.

Google LLC

Google Ireland Limited

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

https://support.google.com/policies/contact/general_privacy_form

Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.

Click here to read the Privacy Policy of the data processor https://policies.google.com/privacy?hl=en 

Click here to opt out from this processor across all domains https://safety.google/privacy/privacy-controls/

Click here to read the Cookie Policy of the data processor https://policies.google.com/technologies/cookies?hl=en

Storage Information

Below you can see the longest potential duration for storage on a device, as set when using the cookie method of storage and if there are any other methods used.

Maximum age of cookie storage: 19 years, 4 days

YouTube Video

This is a video player service.

Processing company

Google Ireland Limited

Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data Purposes

This list represents the purposes of the data collection and processing.

Displaying Videos

Technologies Used

Cookies (if Privacy-Enhanced Mode is not activated)

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• Device information
• IP address
• Referrer URL
• Videos viewed

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes.

Data Recipients

Alphabet Inc.

Google LLC

Google Ireland Limited

Data Protection Officer of processing Company

Below you can find the email address of the data protection officer of the processing company.

https://support.google.com/policies/contact/general_privacy_form

Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing

Worldwide

Click here to read the Privacy Policy of the data processor https://policies.google.com/privacy?hl=en

Click here to opt out from this processor across all domains https://safety.google/privacy/privacy-controls/

Click here to read the Cookie Policy of the data processor https://policies.google.com/technologies/cookies?hl=en

Storage Information

Below you can see the longest potential duration for storage on a device, as set when using the cookie method of storage and if there are any other methods used.

Maximum age of cookie storage: 10 years, 2 days

Google Analytics

This is a web analytics service. With this the user can measure the advertising ROI as well as track Flash, video, and social networking sites and applications.

Processing company

Google Ireland Limited

Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data Purposes

This list represents the purposes of the data collection and processing.

• Analytics
• Marketing
• Technologies Used
• Cookies
• Pixel

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• App updates
• Browser information
• Click path
• Date and time of visit
• Device information
• Downloads
• Flash version
• Location information
• IP address
• JavaScript support
• Pages visited
• Purchase activity
• Referrer URL
• Usage data
• Widget interactions

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The Retention Period depends on the type of the saved data. Each client can choose how long Google Analytics retains data before automatically deleting it.

Data Recipients

Google Ireland Limited, Alphabet Inc., Google LLC

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

https://support.google.com/policies/contact/general_privacy_form

Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.

United States of America,Singapore,Chile,Taiwan

Click here to read the Privacy Policy of the data processor https://policies.google.com/privacy?hl=en

Click here to opt out from this processor across all domains https://tools.google.com/dlpage/gaoptout?hl=de

Click here to read the Cookie Policy of the data processor https://policies.google.com/technologies/cookies?hl=en

Storage Information

Below you can see the longest potential duration for storage on a device, as set when using the cookie method of storage and if there are any other methods used.

Maximum age of cookie storage: 2 years

Essential

These technologies are required to activate the core functionality of the website.

Usercentrics Consent Management Platform

This is a consent management service. Usercentrics GmbH is used on the website as a processor for the purpose of consent management.

Processing company

Usercentrics GmbH

Sendlinger Str. 7, 80331 Munich, Germany

Data Purposes

This list represents the purposes of the data collection and processing.

• Compliance with legal obligations
• Consent storage
• Technologies Used
• Local storage
• Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• Opt-in and opt-out data
• Referrer URL
• User agent
• User settings
• Consent ID
• Time of consent
• Consent type
• Template version
• Banner language
• Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. c GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The consent data (given consent and revocation of consent) are stored for three years. The data will then be deleted immediately.

Data Recipients

Usercentrics GmbH

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

datenschutz(at)usercentrics.com

Click here to read the Privacy Policy of the data processor https://usercentrics.com/privacy-policy/

Google Fonts

This is a collection of fonts for commercial and personal use.

Processing company

Google Ireland Limited

Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data Purposes

This list represents the purposes of the data collection and processing.

Providing fonts

Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

• IP address
• CSS request
• Aggregated usage numbers
• Font file requests
• Referrer URL

Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR

Location of Processing

European Union

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes.

Data Recipients

Alphabet Inc.

Google LLC

Google Ireland Limited

Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.

https://support.google.com/policies/contact/general_privacy_form

Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.

Worldwide

Click here to read the Privacy Policy of the data processor https://policies.google.com/privacy?hl=en

Click here to opt out from this processor across all domains https://safety.google/privacy/privacy-controls/

Click here to read the Cookie Policy of the data processor

https://policies.google.com/technologies/cookies?hl=en

How you can contact HOBART UK?

If you have any questions, comments or concerns about this Privacy Notice or the information practices of this site, please contact us at:

HOBART UK

Southgate Way, Orton Southgate, Peterborough PE2 6GN

Compliance and Cooperation with Regulatory Authorities

We review our privacy notice on a regular basis. Our procedures and practises are in line with the GDPR set by the EU, which will remain the case after the UK has left the EU. For more information, please contact If you want to request information or discuss any aspects of our privacy policy you can email us at privacy(at)hobartuk.com

Changes to the Notice

Hobart UK reserves the right to update or modify this Cookie Notice, at any time and without prior notice, by posting the revised version of this Cookie Notice on our Hobart UK Website. If we modify this Privacy Notice, the modifications will only apply to personal information we collect after we have posted the revised Cookie Notice on the Website.

ITW Limited and each of its business units in the United Kingdom (“ITW”), including Hobart UK, has a long tradition of establishing and complying with high standards of business behaviour, standards which often exceed the applicable laws and regulations of those countries in which it operates. It has been and will continue to be the policy of ITW to comply with all applicable laws.

In the complex area of competition law, the Board of Directors of ITW has issued a Compliance Policy and Manual to help ITW personnel understand and comply with UK and EU competition laws. The Board of Directors and all employees of ITW share a commitment and a responsibility to compete fairly and honestly on the basis of price, quality and service, and in full compliance with law and with ITW’s competition policy.

ITW Modern Slavery and Human Trafficking Statement

This Statement relates to our fiscal year ended December 31, 2019. It describes the activities of Illinois Tool Works Inc and its consolidated subsidiaries (the “Company,” “ITW,” “we,” “us” and “our”) to eliminate slavery and human trafficking from its business and supply chains.

Overview

ITW recognizes that our impact extends far beyond our own walls. To further our positive impact on our shared world, we are committed to fostering responsibility across our value chain,through the impact of our products, as well as via our global supplier network.

The Company is a global manufacturer of a diversified range of industrial products and equipment with 84 divisions in 53 countries. 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 Labor 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.

We have prepared this Statement on a combined basis to comply with both the California Transparency in Supply Chains Act and the UK Modern Slavery Act and for our entire company, because our Core Values, Statement of Principles of Conduct, Human Rights Policy, Supplier Code of Conduct, Supplier Expectations and Conflict Minerals Policy Statement, together provide the over-arching compliance framework relating to slavery and human trafficking across our entire enterprise (which we sometimes refer to herein collectively as “modern slavery”). However, not all of the entities that are part of the Company are subject to the California Transparency in Supply Chains Act or the UK Modern Slavery Act.

We believe that the risks of modern slavery in our own businesses are remote given the nature of our businesses and workforce coupled with our internal policies and procedures. Where we have identified risks inherent in suppliers, as further discussed below, we have established procedures to mitigate the risks of modern slavery in our supply chains for products from those suppliers.

Where practicable, we seek to maintain long-term relationships with local suppliers, to help ussource more responsibly and reduce the risk of sourcing from an unethical supplier.

Codes of Conduct

The ITW Statement of Principles 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 laws against slavery, human trafficking and child labor. The ITW Statement of Principles of Conduct applies to all of our employees and internal business
operations.

In addition, ITW’s Supplier Code of Conduct holds our suppliers accountable to the same standards of conduct set forth in our Statement of Principles of Conduct. The Supplier Code of
Conduct specifically prohibits our suppliers from employing workers that are younger than minimum age (and in any case, under the age of 15) or from knowingly sourcing from suppliers associated with human trafficking. The Supplier Code of Conduct also requires our suppliers to take reasonable efforts to ensure that their suppliers comply with our policies. We expect our suppliers to be in compliance with the Supplier Code of Conduct, and we do not knowingly do business with suppliers who violate laws for the protection of human rights or human health and safety.

We also have published Supplier Expectations. Among other things, our Supplier Expectations indicate that we expect suppliers to comply with all applicable laws and regulations around the globe, including those pertaining to human rights and laws against slavery, human trafficking and child labor.

Furthermore, we have published a Human Rights Policy. Our Human Rights Policy indicates that we are committed to human rights in the workplace. Among other things, this includes providing a workplace that protects employee well-being and safety and compliance with all applicable laws regarding slavery, human trafficking and child labor.

Steps to Mitigate Slavery and Human Trafficking Risk

We engage in the activities discussed below to mitigate the risk of modern slavery in our supply chains.

Consistent with our decentralized operating structure, our individual businesses are responsible for assessing and addressing risks of modern slavery in their supply chains, based on their particular business and risk profile. In recognition of the different risk profiles of our businesses,we have elected not to take a prescriptive approach to this area of compliance as we believe that enabling individual businesses to take a thoughtful, tailored approach to addressing modern slavery risk is more effective than a prescriptive approach, and our business units are expected to operate in accordance with our Core Values, the ITW Statement of Principles of Conduct, theSupplier Code of Conduct, the Supplier Expectations, the Human Rights Policy and other ITW policies.

Supplier and Risk Assessments; Supply Chain Verification. Our businesses evaluate prospective suppliers during supplier selection and periodically thereafter based on their business and risk profile and role in our supply chain. The evaluation may include steps to assess risks of modern slavery. The steps taken to assess modern slavery risk typically include a request that suppliers complete a supplier questionnaire detailing supplier capabilities related to manufacturing processes, quality control, delivery, and technology, and requesting other
information relative to overall management of the supplier company

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ITW also conducts internal research relating to modern slavery risk using U.S. government and non-governmental organization resources, conducts supplier outreach in connection with our conflict minerals country of origin inquiries and participates in industry groups and engagement with other stakeholders. As part of our supplier risk assessment process, we also use a proprietary supply chain risk checklist that guides us in identifying suppliers with the highest risks of modern slavery in their operations. In addition, as discussed below, we require
certifications from the highest risk suppliers.

Audits. Prior to placing business with a supplier, an onsite supplier visit may be made by ITW personnel for purposes of confirming supplier 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 modern slavery, compliance with Company standards for modern slavery is covered within the overall supplier assessment, and we believe that onsite supplier visits by ITW personnel discourage abusive working conditions.

Contract Terms. Our standard Terms and Conditions of Purchase provide that direct suppliers must comply with all applicable laws against slavery, human trafficking and child labor. Terms and Conditions of Purchase also require direct suppliers to comply with our Supplier Code ofConduct.

Supplier Certifications. We evaluate our purchased products against the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor for likely countries and industries prone to modern slavery to help identify high-risk suppliers ITW may utilize. Based on this evaluation, we provide education on our Supplier Code of Conduct to identified possible high-risk suppliers and ask them to sign a declaration that they are aware of and comply with our Supplier Code of Conduct, including its provisions regarding slavery and human trafficking. We have obtained certification of compliance from 100 percent of these identified possible high-risk suppliers.

We require annual re-certifications from any identified high-risk suppliers. In addition, we require substantial suppliers who sell us product that contains so-called “conflict minerals” to certify as to the origin of the minerals or other requested material to determine whether such minerals or materials may be supporting conflict in central Africa. These certifications are in part intended to help identify and mitigate the risk of modern slavery, human trafficking, child labor and other violations of human rights.

Grievance Mechanism. The Company maintains a confidential whistleblower help line by which all employees, suppliers and other third parties may report compliance failures by employees,suppliers or contractors, including with respect to modern slavery. The contact information for our helpline is http://www.itwhelpline.ethicspoint.com

Internal Accountability and Training

Compliance Team. At the corporate level, we have a Responsible Sourcing Committee that meets regularly on human rights and other topics related to responsible sourcing. Employees at our decentralized business units also are involved in compliance efforts and are responsible to ensure they are sourcing appropriately, including consideration of the risks related to modern slavery in the supply chain.

Training and Knowledge Management. Our sourcing personnel are trained in overall supplier expectations, including the requirement to act ethically and according to our Supplier Code of Conduct. In addition, we require our global sourcing employees, global employees who work withsuppliers and customers on conflict minerals requests, and our Responsible Sourcing Committee members to undergo specific modern slavery training intended to generate awareness and examples of best practices, particularly with respect to mitigating risks within our product supply chains, and to enable our sourcing professionals to better recognize the signs of modern slavery and act to address any identified issues. In 2018, we enhanced the content of our modern slavery training and expanded the group of employees required to undergo such training to the groups mentioned above. In 2019, we continued providing enhanced training to all new employees in those groups. We also host an internal website that contains this training and additional materials on this topic. To date, no issues of concern have been identified by our personnel regarding any potential modern slavery at our suppliers.

Employee Certifications. Employees are periodically required to certify to their compliance with the ITW Statement of Principles of Conduct. In addition, our modern slavery training,
mentioned above, also requires the employee groups described above to undergo periodic certification of compliance.

Additional Corporate Social Responsibility Efforts

For more information on our efforts and our achievements relating to corporate social responsibility, see our Corporate Social Responsibility Report, which is available at

http://www.itw.com/social-responsibility/.

Solely for purposes of compliance with the UK Modern Slavery Act, this Statement was approvedby the Board of Directors of ITW Limited on June 24, 2020 and signed by a director of that entityas indicated below.

Giles Hudson, Director
June 24, 2020