Code of Business Conduct
Employees are required to abide by H.B. Fuller’s Code of Business Conduct.
Human Rights Policy
Supply Chain Transparency
H.B. Fuller Company does not knowingly purchase goods or services produced using forced labor, child labor or in violation of any applicable local labor laws. Our standard purchase order requires that our suppliers comply with all applicable Federal, State or Local Laws, Rules, Regulations, Ordinances and Executive Orders. Employees are required to abide by H.B. Fuller’s Code of Business Conduct.
Conflict Minerals Policy
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 directed the U.S. Securities and Exchange Commission (“SEC”) to adopt a rule requiring public companies with conflict minerals (tin, tantalum, tungsten, and gold) that are necessary to the functionality or production of products manufactured or contracted to be manufactured by such companies to disclose annually whether any of those conflict minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country. The rule is intended to further the humanitarian goal of ending the extremely violent conflict in the DRC which has been financed in part by the exploitation and trade of conflict minerals originating in the DRC. H.B. Fuller Company and its majority-owned subsidiaries (“H.B. Fuller”) are committed to ethical business practices, with respect for human rights and in compliance with all applicable laws and regulations. We are committed to complying with the SEC’s rule on conflict minerals and the responsible sourcing of minerals through our global supply chain. We are actively and diligently working with our global supply chain partners to determine the origin of any conflict minerals they may supply to us, and will continue to work with them towards the goal of providing greater supply chain transparency and responsible sourcing. Our due diligence measures follow the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for the Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas in all material respects. Suppliers who are materially non-compliant with the SEC’s rule on conflict minerals will be reviewed by our sourcing managers for future business. In the event H.B. Fuller determines that a supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, H.B. Fuller reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.
Last revised: July 2021
Moden Slavery and Human Trafficking Statement
H.B. Fuller Company is opposed to all forms of exploitation and forced labour and is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Code of Business Conduct, which includes our Fair Treatment Core Policy, reflects our commitment to acting ethically and with integrity in all our business relationships. As part of this commitment, and bearing in mind the changing landscape globally 52b (cultural shifts and enhanced expectations, as well as developing regulations around the world), we review, update and implement systems and controls to counter the risk of facilitating modern slavery or human trafficking.
Within our Conditions of Purchase, through which we do business with the majority of our suppliers, we make clear our position on modern slavery and human trafficking and other ethical/compliance requirements. We further emphasize this stance within a Supplier Expectations letter, which specifically forms part of new supplier contracts. To promote and to allow suppliers easier access to these expectations, we have set up a ‘Supplier page’ on our publicly available website: https://www.hbfuller.com/suppliers.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide training to our employees and will continue to do so in the future. We regularly refresh and refine our training to ensure its effectiveness. Our HBF Path Helpline is a channel through which we aim to protect and support reporting by our employees and third parties.
Looking forward, our goal is to continue to deliver improvements on our ongoing assessment of risk areas in our supply chain, including regular supplier assessments. We will be ensuring that the H.B. Fuller group around the world, including more recently acquired businesses, is consistent in its approach and our work with the Sourcing group will be a key part of this drive towards delivering improvements.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes H.B. Fuller Company’s slavery and human trafficking statement for the financial year ending December 2, 2023.
Nathan Weaver
Senior Vice President, Human Resources