Proprietary Information

Revision Approved By: Casey Cullen 08/19/2020

During the course of your employment you will learn or have access to information which Spectrum Brands considers proprietary. You are required to maintain the confidentiality of information entrusted to you by Spectrum Brands and/or its customers and consumers.

Spectrum Brands generally considers the following information proprietary:

• Vendors and/or suppliers utilized by Spectrum Brands

Example: Parts suppliers, raw materials suppliers, factories, consultants, staffing agencies

• Production or manufacturing techniques

Example: If a part is machined or stamped, if a part is injection molded, how an item is painted or coated

• QI analysis procedures

Example: The tests performed on a product during quality analysis and/or the testing capabilities of our quality lab

• QI analysis results

Example: The findings of any quality analysis tests performed on a returned product

• Consumer complaint trends

Example: Whether or not other consumers have expressed the same complaint, that other consumers have shared the same complaint, that a complaint or concern is “common”

• Data analysis techniques and procedures

Example: The reason codes we use, how reason codes are organized, how transactions are coded, the reports we generate, how reports are configured

• Consumer information

Example: All names, addresses, phone numbers, email addresses, whether or not a person has contacted us in the past, if a person is in our database (does not apply to consumers asking about themselves)

• Means of consumer appeasement in excess of warranty obligations

Example: If a certain concern, problem or type of problem has previously resulted in offers to refund a product, upgrade a product, provide additional product, provide gestures of goodwill, or any other means of appeasement in excess of warranty obligations to any consumer

How to respond to general inquiries about proprietary information:

Generally, you should advise the consumer that you cannot supply the information they requested and move the conversation along. For example:

• “I’m sorry; I don’t have access to that information as it is considered proprietary. Is there anything else I can help you with?”

• “I’m sorry; I can’t comment on that as its proprietary information. However, I’ve placed the order for your part and that should take care of this problem.”

How to respond to inquiries about complaint trends, such as if a problem is common, or if you’ve heard a specific complaint before:

You may inform the consumer their complaint is not common – this is a true statement when you consider the quantity sold compared to the number of complaints. Otherwise, address their question without providing proprietary information and move the call along. For example:

• “I can assure you this isn’t a common complaint, but I’ll make sure we get this problem taken care of for you. First, I’d like to ask a few troubleshooting questions…”

• “I don’t have that information available but I’m sure it’s not a common problem. Let me see how I can take care of this for you.”

• “No, I don’t hear of this issue very often, but let me see what I can do to help.”

• “I’m sorry, I help many people with questions about many products every day; I can’t really say whether I’ve heard this specific complaint before. But, I’m sure you’ll have a better experience with the replacement product I’m having sent to you. Is there anything else I can help you with today?”