Updated May 2024
This statement is made pursuant to Canada’s Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act (“Canada’s Act”). In support of the act, this statement sets out the steps that Douglas Machine, Inc. and its subsidiaries (“DMI”) took during the fiscal year ending December 31, 2023, and continue to take to mitigate the risk of modern slavery and human trafficking within our business and supply chain.
Policies & Due Diligence
DMI’s mission is, “to enrich lives by providing differentiated packaging automation and services.” This is followed by DMI’s values, “the core of our values is an abiding respect for Biblically-based business principles. To us this means conducting business in a manner that is legal, ethical, moral and healthy to the faith-based spiritual life of every employee owner, customer, supplier and competitor.” Under the values are the following Biblically-based business principles:
- Unwavering Integrity
- Servant’s Heart
- Ownership Spirit
- Continuous Innovation & Improvement
It is under the company’s mission, vision and business principles there is assurance relevant due diligence and processes are in place. In particular, under Unwavering Integrity the pertinent behaviors are:
- We do what is right.
- We treat others the way we wish to be treated.
- We do not compromise the safety or well-being of others or ourselves.
If an instance of forced labor or child labor became known, DMI would be highly engaged to immediately resolve and remediate.
Prevention & Reduction of Risk
All employment positions are applied for voluntarily, which, if selected, is followed by a voluntary interview. If the applicant is the finalist selected for the position, an offer is extended. The candidate has a voluntary decision to accept or decline the offer. If they choose to accept the offer, they sign and return the offer document indicating their acceptance. The offer document notifies the applicant that their employment is at will, and that they have the right to quit at any time for any reason or no reason.
DMI is also compliant with the state of Minnesota’s employment laws. One in particular is the stringent review and acceptance into the Minnesota Youth Skills Training program. This program allows DMI to hire 16 and 17 year olds to work in a manufacturing environment, but under strict requirements.
Remediation
DMI has not started the process of identifying forced labor and child labor risks within its supply chain. However, DMI makes it distinctly clear such practices of forced labor and child labor will not be tolerated. This is evidenced by company standard 00418, Human Trafficking and Slavery Statement:
Douglas Machine Inc. is committed to acting in a responsible manner as stated in the preamble of the company values:
The core of our values is an abiding respect for Biblically-based business principles. To us this means conducting business in a manner that is legal, ethical, moral and healthy to the faith-based spiritual life of every employee owner, customer, supplier and competitor.
These values include adhering to supply chain laws and regulations regarding human trafficking and slavery, such as the California Transparency in Supply Chains Act of 2010. OEM’s and suppliers of OEM’s, however, may be far removed from the source of supply. Because Douglas Machine Inc., an OEM, purchases thousands of items that are manufactured by hundreds of domestic and international companies, primarily through a network of distributors, it is not possible to trace human trafficking and slavery back to their source with 100% certainty.
Additional Information
Forced labor or child labor has not been observed or reported in any of DMI’s owned and operated locations. Furthermore, DMI uses contract labor as well and was assured migrant labor is required to submit an I-9 form before employment. Because of this, DMI has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labor or child labor in activities and supply chains.
In addition, DMI has grievance mechanisms in place should violations occur. As outlined in the company employee handbook, employees are encouraged to raise concerns to their supervisor or directly to the human resources department.
The human resource team and hiring managers are trained on what can and cannot be said during interviews. The training is for all aspects of the hiring process, which includes current state and national labor laws.
DMI has policies and procedures in place to assess effectiveness in ensuring that forced labor and child labor are not used in its activities. However, policies and procedures to assess effectiveness of the supply chain are not formally in place. Nonetheless, the company’s procurement team is in constant communication with suppliers. Part of the ongoing communication with suppliers includes conducting business with a very high degree of business ethics.
DMI values the dignity of all human life, which aligns with our abiding respect for Biblically-based business principles. To this end, we will remain focused on this very important human tragedy and do our part stop forced labor and child labor.
Approval for this Statement
Name: Jon Ballou
Title: Executive Chairman
Date: May 24, 2024