Introduction
T.D. Williamson ("TDW" or “the Company”) is committed to responsible sourcing and, specifically, the elimination of human trafficking and slavery in our supply chain, if any. TDW has a zero-tolerance policy on the use of modern slavery and forced labor practices by its subsidiaries, officers, employees, and suppliers, in accordance with the principles set forth in the United Nations Guiding Principles on Business and Human Rights and the Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises. TDW is committed to the respect of all human rights included in the International Bill of Human Rights and the International Labour Organization’s core labor rights conventions.
Our commitment to human rights and ethical sourcing practices is reflected in our policies, including the TDW Code of Business Conduct and Ethics and our Anti-Slavery and Forced Labour Policy.
Supply Chain
With five manufacturing sites and multiple service centers spread across four continents, TDW’s procurement organization is responsible for purchasing products and services from external partners that include suppliers in the Americas, Europe, Middle East, and Asia Pacific regions. The procurement structure includes a strategic sourcing team of commodity managers responsible for managing purchases.
Risk Assessment and Verification: TDW’s intake and onboarding process for suppliers includes a verification process in which the Company assesses supplier risk based on factors including high-risk locations, industries, and manufacturing processes to evaluate risks and vulnerability to slavery or human trafficking in the production of supplier goods. TDW utilizes third-party compliance software and service providers to conduct initial assessments and continual monitoring of those suppliers throughout the life of the business relationship.
TDW’s contractual provisions require suppliers to comply with all applicable laws and act in a manner consistent with TDW’s Code of Business Conduct and Ethics which expressly states that TDW “has a long-standing commitment to upholding fundamental human rights around the world [which include] safe working conditions, individual security and prohibitions against forced labor, child labor and human trafficking.” In its agreements with its suppliers, TDW reserves the right to conduct onsite audits of prospective and existing suppliers' manufacturing facilities. TDW conducts audits of its key suppliers selected by sales volume and geographic risk. Audit frequency and scope is determined based on risk assessments, and TDW is continuing to improve its processes to track and report audit outcomes to enhance transparency and accountability.
Accountability Standards: TDW's Code of Business Conduct and Ethics includes a policy setting out its accountability standards with respect to the Company’s values and standards and provides that any employee who violates the Code of Business Conduct and Ethics will be subject to disciplinary action. The Code applies to all employees, directors, and officers of the Company and sets clear expectations regarding ethical labor practices, including prohibitions against forced labor, child labor, and human trafficking.
To support compliance and worker protections, TDW implemented mechanisms to help workers understand the Company’s fair labor standards, including procedures for reporting violations through confidential and anonymous channels. Reports of labor violations, including human trafficking concerns, will be reviewed under TDW’s whistleblower policy, which protects employees and workers from retaliation for reporting ethical concerns in good faith.
Training: All TDW employees receive annual training on the principles and policies contained in the Company’s Code of Business Conduct and Ethics. TDW is developing targeted training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks within the supply chain and key topics such as identifying human trafficking risks, recognizing forced labor indicators, and enforcing TDW’s supplier standards.
This statement complies with the requirements of the Norwegian Transparency Act, the UK Modern Slavery Act 2015, and the California Transparency in Supply Chains Act.
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