California Transparency in Supply Chains Act

Fort Dearborn Company expects our suppliers to comply by applicable laws and behave in an ethical manner. We are committed to mitigating the risk of slavery and human trafficking in our supply chain. The California Transparency in Supply Chains Act of 2010 requires companies conducting business in the state of California to disclose the efforts they take to eradicate slavery and human trafficking from their direct supply chains for goods offered for sale. The act requires disclosures regarding verification, auditing, certification, internal accountability and training.

1. Verification of Suppliers: Fort Dearborn’s internal Procurement compliance team conducts verifications of its top 20 suppliers (of substrates, ink and temporary employment) to assess and manage the risks of human trafficking and slavery laws in its supply chain.
2. Supplier Audits: Fort Dearborn does not conduct suppliers audits specifically for the California Chains Act. As part of our supplier qualification process, we do require that our top 20 suppliers meet and certify that they comply with all applicable laws as it relates to human trafficking and slavery.
3. Supplier Certifications: Fort Dearborn maintains Certification Letters of Compliance with slavery and human trafficking laws for each of our top 20 suppliers. Suppliers are required to certify that they comply with the labor laws of the countries in which they do business, and must provide prompt notification of any change in certification or failure to comply, including providing corrective actions and timelines for remediation. Fort Dearborn Company reserves the right to verify compliance and terminate a supplier agreement for failure to comply.
4. Internal Accountability: Our associate handbook, which contains our Business Code of Conduct, is being updated for 2016 to incorporate company standards regarding slavery and human trafficking laws. Each employee will be required to sign and acknowledgement of receipt of the handbook. The Company’s Director of Human Resources will maintain a log of all acknowledgements. The Company reserves the right to verify compliance, mandate corrective actions and/or terminate an employee for failure to comply with company standards.
5. Associate Training: Our supply chain management staff consists of one vice-president and one director. Every member of our supply chain management staff receives training on all company policies, practices, and procedures designed to ensure that our supply chain is free of any type of coerced labor.