Policy on Combating Modern Slavery in the Colour Trade
At Bauwerk Colour, we are committed to upholding the highest ethical standards in our operations and supply chains. We strongly oppose all forms of modern slavery, including forced labor, child labor, human trafficking, and exploitative working conditions. This policy aligns with the OECD Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and international human rights frameworks such as the UN Guiding Principles on Business and Human Rights.
As a company engaged in the paint and coatings industry, we recognize the risks associated with the sourcing of raw materials, including cobalt, which is widely used in pigments and color production. We are committed to a responsible cobalt supply chain that ensures ethical and sustainable sourcing practices.
Scope
This policy applies to all employees, suppliers, contractors, and business partners involved in the procurement, production, and distribution of color-related products. It specifically affects companies that are directly or indirectly part of our supply chain. This includes manufacturers, raw material suppliers, logistics partners, and subcontractors. We expect all parties to uphold the highest ethical standards and comply with our human rights commitments.
Core Commitments
- Zero Tolerance for Modern Slavery: We prohibit the use of forced labor, child labor, bonded labor, and any form of human trafficking in our operations and supply chains. We require our suppliers and partners to demonstrate their compliance with global labor standards and ensure that all work is voluntary, with fair wages and freedom of movement.
- Fair and Safe Working Conditions: We mandate that all employees, contractors, and supply chain workers operate in environments that are safe, healthy, and free from harassment and discrimination. Employers must provide proper protective equipment, reasonable working hours, and transparent labor contracts that outline workers’ rights and obligations.
- Remediation and Corrective Actions: If any supplier or partner is found to be in violation of our anti-slavery policy, we will work collaboratively to implement corrective measures, including training, process improvements, and worker remediation programs. Failure to comply may result in the termination of contracts and business relationships.
Employee and Supplier Awareness
We recognize that effective implementation of this policy requires awareness and commitment across our organization and supply chain. Therefore, we will:
- Provide comprehensive training for employees, particularly those in procurement, supply chain management, and compliance roles, to recognize and address modern slavery risks.
- Develop training materials that outline real-world examples of modern slavery, indicators of forced labor, and best practices for preventing human rights abuses.
- Establish a continuous learning process that incorporates feedback, case studies, and new developments in human rights due diligence.
- Foster a corporate culture where employees and partners feel empowered to report concerns about unethical practices without fear of retaliation.
Compliance and Monitoring
To ensure compliance with this policy and prevent modern slavery, we will:
- Implement contractual clauses requiring suppliers to adhere to ethical labor practices and conduct regular self-assessments.
- Establish a supplier code of conduct that explicitly prohibits forced labor, child labor, and other forms of exploitation.
- Develop clear escalation procedures for dealing with non-compliance, including warnings, remediation plans, and, if necessary, termination of business relationships.
- Regularly review and enhance our compliance framework to align with evolving human rights standards and best practices.
- Each supplier is assessed to review the level of compliance with this policy and to identify potential risks related to compliance.
Responsible Cobalt Supply Chain Policy
Freeport Cobalt Oy (FCO) is committed to operate based on strict safety, environmental and ethical standards as outlined by Freeport McMoRan Inc. corporate policies. This policy is developed to adopt the corporate policies as well as the OECD Guidelines for Responsible Supply Chain of Minerals from Conflict Affected and High Risk Areas to the sourcing of cobalt raw materials to meet stringent expectations of various stakeholders.
FCO commits itself to manage its cobalt raw material supply chain based on the five step framework in Annex 1 of the OECD guidelines:
- Establish strong company management systems
- Identify and assess risk in the supply chain
- Design and implement a strategy to respond to identified risks
- Carry out independent third party audit of supply chain at identified points
- Report on supply chain due diligence
Cobalt raw material suppliers and their sub-suppliers are expected to conduct their activities and operations in a responsible manner as described in the attached Supplier Code of Conduct.
Minimum Expectations
- Suppliers must comply with all applicable local and international laws and regulations.
- Suppliers must demonstrate their intent and strive for high operating standards in the areas of safety, environment and business ethics.
- Suppliers must be able to track and maintain custody of their raw material flow from the mine site to the delivered product.
- Suppliers must cooperate with FCO to conduct on site evaluations to assess compliance with this policy.
Whistleblowing System and Reporting Obligations
We are committed to fostering an open and transparent environment where employees, suppliers, and external stakeholders can report concerns regarding modern slavery. To achieve this, we will:
- Maintain a secure and anonymous whistleblowing system that allows individuals to report suspected violations confidentially.
- Ensure that all reports are thoroughly investigated by our compliance team or an independent third party.
- Implement protective measures to prevent retaliation against whistleblowers and encourage responsible reporting.
- Take appropriate remedial action against individuals or entities found to be in violation of this policy.
- Publish an annual report outlining key findings, actions taken, and continuous improvements in our modern slavery prevention efforts.
Review and Updates
This policy will be reviewed annually and updated as necessary to reflect changes in laws and best practices.
By implementing and continuously improving this policy, Bauwerk Colour ensures compliance with human rights. We remain committed to fostering a fair, ethical, and sustainable global supply chain.