Legal Notices


Code of Business Conduct

Employees are required to abide by H.B. Fuller’s Code of Business Conduct.

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.

Supplier Expectations Letter 

Conflict Minerals Policy

This document contains H.B. Fuller’s statement regarding the use of conflict minerals in our products. As used in this policy, “H.B. Fuller” includes H.B. Fuller Company and its majority-owned subsidiaries, as applicable, unless otherwise noted.

Regulatory Background

On August 22nd, 2012, the United States Securities and Exchange Commission (the “SEC”) adopted a final rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Conflict Minerals Rule”). The Conflict Minerals Rule is intended to reduce a significant source of funding for armed groups that are committing human rights abuses in the Democratic Republic of Congo (the “DRC”) and its adjoining countries.

Under the Conflict Minerals Rule, to the extent that “conflict minerals” are necessary to the functionality or production of products that H.B. Fuller manufactures or contracts to manufacture (the “Covered Products”), the SEC requires H.B. Fuller to conduct supply chain due diligence to determine whether the conflict minerals originated in the DRC or one of its adjoining countries. The DRC and its adjoining countries are collectively referred to under the rule as “covered countries.” In addition to the DRC, the covered countries include: Angola; Burundi; Central African Republic; the Republic of the Congo; Rwanda; South Sudan; Tanzania; Uganda; and Zambia. The minerals (and derivative metals) covered by the Conflict Mineral Rule include: Cassiterite (Tin); Columbite-tantalite (Tantalum); Wolframite (Tungsten); and Gold. The Conflict Minerals Rule defines these minerals (sometimes referred to as “three Ts and gold” or “3TG”) as “conflict minerals,” regardless of their country of origin.

Publicly traded companies must report annually to the SEC the presence of conflict minerals originating in the DRC and its adjoining countries in products that they manufacture or contract to manufacture if those conflict minerals are necessary to the functionality or production of the products.

H.B. Fuller’s Policy with regard to the Conflict Minerals Rule

H.B. Fuller Company is committed to ethical practices and compliance with applicable laws and regulations, including SEC regulations and the Conflict Minerals Rule. As a public company that manufactures or contracts to manufacture products that may contain conflict minerals, H.B. Fuller is working with its suppliers to determine whether the conflict minerals in its products originated from a covered country and if so, to determine if it is a source of funding for armed groups. We recognize that there may be multiple layers in the supply chain between our suppliers and the smelter of the conflict minerals that are in or may be in the goods that are supplied. Most of our products are not Covered Products, but for the small number that are, we do not generally source conflict minerals directly from the source of supply (mines, smelters, refiners). Therefore, we are generally removed by several levels from the ultimate source of conflict minerals. Because of this, we will use reasonable due diligence to identify the source of the conflict minerals, realizing that this will require the cooperation of our suppliers to meet our compliance obligations.

H.B. Fuller does not knowingly support any action which provides funding, or any form of support, for armed groups that are committing human rights abuses in the DRC and its adjoining countries. Our goal is to comply with the Conflict Minerals Rule and continually gain more transparency in our supply chain. We recognize that, due to the complexity of our supply chain, this goal will take time and effort. To comply with the requirements of the Conflict Minerals Rule, we will: understand the Conflict Minerals Rule and its background;
communicate and educate our personnel, suppliers and customers regarding the Conflict Minerals Rule and we will urge our suppliers to establish policies to ensure that any conflict minerals used in our products are conflict-free and to comply with this rule and provide all necessary declarations; create processes and procedures to conduct a reasonable level of supply chain due diligence and to comply with applicable SEC reporting requirements; and endeavor efforts to source from conflict-free suppliers. H.B. Fuller values its supplier and customer relationships. H.B. Fuller is initially focusing most of its efforts on its most significant top-tier suppliers of goods that contain conflict minerals, and over time expects to extend that focus to small suppliers deeper in the supply chain. Suppliers who are materially non-compliant will be reviewed by our sourcing managers for future business.

This policy will be reviewed and revised from time to time, as needed.

Last revised: May 30, 2014

Modern Slavery and Human Trafficking Statement 

H.B. Fuller Company 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, we continue to review and aim to implement effective systems and controls.

We recently updated our Conditions of Purchase, through which we do business with our suppliers, to make clearer our position on modern slavery and human trafficking and other ethical/compliance requirements. We further emphasize this stance within a Supplier Expectations letter, also recently updated, which specifically forms part of all new supplier contracts so far as we are able to negotiate this with suppliers. To promote and to allow suppliers easier access to these expectations, this year we also rolled out a new ‘Supplier page’ on our publicly available website:

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we have provided training to our employees and will continue to do so in the future. Next year we hope to refresh and refine our training to ensure that it is most effective. To this end, we will work further with our Sourcing group to identify, assess and monitor potential risk areas across our supply chain.  We will review our due diligence and ongoing assessment of suppliers.

Our HBF Path Employee Helpline process is a channel through which we aim to protect and support reporting and whistle blowing by our employees. We might consider expanding access to our Helpline to other individuals in order to enhance potential reporting of noncompliance with our Code of Business Conduct.

Our goal for next year is to deliver improvements on our ongoing assessment of risk areas in our supply chain, and to ensure that the H.B. Fuller wider group around the world, including more recently acquired businesses, is consistent in its approach. 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 3, 2020.



Download Statement 

Supplier Expectations Letter 

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