Legal Notices

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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

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 for Workers Core Policy, reflects our commitment to acting ethically and with integrity in all our business relationships. Ultimately, as part of this drive and commitment, we will continue to implement effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our business or supply chain.

As part of our initiative to mitigate risk regarding the modern slavery issue we have updated our Conditions of Purchase, through which we do business with our suppliers, to reference our requirements specifically. In addition, we have emphasized our requirements within a Supplier Expectations letter, a copy of which is attached. This letter was issued in May 2016 to current suppliers comprising 80% of our annual spend in each of the regions (The Americas, EIMEA and Asia Pacific) and is included within the Welcome Pack issued to all new suppliers. The letter also forms part of all new supplier contracts, so far as we are able to negotiate this with 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 have provided training to our staff and will continue to do so in the future. The training is conducted either directly in appropriate team meetings (focusing on the Sourcing group) or via on-line modules where questions are embedded for the participant to answer before being deemed to have passed the module.

We will continue to work with our Sourcing group to identify, assess and monitor potential risk areas in order to mitigate the risk of slavery and human trafficking occurring in our supply chain. We will review our due diligence and ongoing assessment of suppliers.

We are confident that our HBF Path Employee Helpline process is effective in protecting and supporting reporting and whistle blowing by our employees. We will consider expanding access to our Helpline to other individuals in order to enhance potential reporting of noncompliance with our Code of Business Conduct.

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, 2016.

PAULA COONEY
VICE PRESIDENT, HUMAN RESOURCES

Download Statement 

Supplier Expectations Letter 

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