Forced Labor and Child Labor Report for Rite-Hite International, Inc.
2023 Annual Report
Introduction
This report (“Report”) is made in compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) by Rite-Hite International, Inc. The terms “Rite-Hite International”, “we”, “our”, and “the Company” refer to Rite-Hite International.
We recognize that risks of forced labor and child labor exist and acknowledge that understanding and managing these risks requires a collaborative approach with our suppliers, our workforce and other external stakeholders. This Report outlines our processes, existing measures, and progress made in the 2023 fiscal year to prevent and mitigate the risks of forced labor and child labor across the supply chain we utilize. This Report was prepared for the calendar year ended December 31, 2023, and approved by an officer of the Company.
Our Structure, Business and Supply Chain
Rite-Hite International is a privately held company, headquartered in Milwaukee, WI, USA, doing business in Canada under Business Number: 132647108RM0002. The Company operates in the core business of loading dock safety equipment, with approximately 500 employees worldwide, including approximately 75 within Canada.
Our product solutions include loading dock levelers, vehicle restraints, industrial doors, loading dock shelters and various complimentary in-plant product offerings. We offer many of our own company manufactured products as well as outsourced products from various vetted allied vendors.
A key component of our supply chain is to ensure suppliers meet our qualification standards and corporate requirements. Within our supply chain, we track key supplier metrics including spend, performance history, capabilities, discrepancies, and non-conformances.
Our Policies, Standards and Due Diligence Processes
Compliance with Laws
We are committed to the highest standards of integrity, ethics and performance relating to social responsibility and compliance. As such, we expect our Suppliers and Business Partners, and their designated manufacturing facilities and subcontractors, to at a minimum, fully comply with all applicable national and/or local laws and regulations in the countries where the Suppliers and Business Partners operate, including but not limited to those related to forced labor and child labor. We will cease conducting business with Suppliers or Business Partners who are found to provide product or materials that fail to comply with the laws of the country or countries in which they are doing business.
Voluntary Labor
All labor must be voluntary. Child (workers under the age of 14 regardless of local and national regulations), underage, forced, bonded, slave or indentured labor will not be tolerated. Suppliers and Business Partners must ensure that they provide workers with rest days and must ensure that working hours are consistent with regulation and not excessive. We refrain from purchasing products from, or otherwise doing business with, companies whose products are made utilizing underage, forced, bonded, indentured, trafficked or slave labor. On an ad hoc basis, or in response to an allegation, we will (or, if the circumstances dictate, retain an independent third party) audit Suppliers and Business Partners to evaluate and address such risks. On an ad hoc basis, or in response to an allegation, we may require our Suppliers or Business Partners to certify that materials incorporated into its products comply with applicable law regarding voluntary labor. We will not do business with those who are found to provide product or materials that fail to comply with our voluntary labor standards.
Forced Labor Risks
Our greatest risk exposure to forced labor and child labor is through suppliers, and the primary sources of these risks come from procuring goods in higher-risk geographies and sectors. We recognize the potential risks of forced labor and child labor in our extended supply chain and the complexity and challenges in operationalizing forced labor compliance.
Our Actions to Address Forced Labor Risks
Supplier Registration and Vetting
We leverage various processes to screen and monitor suppliers and our global supply chain for human rights risks, including forced labor and child labor. All vendor purchasing documentation includes our policies and standards, and our compliance standards are stated on our website.
Our Training, Awareness and Expectations on Reporting Violations
We are committed to developing a resilient and transparent supply chain where the human rights of every worker involved are respected. We publish relevant policies and standards prominently on our website and we provide company employees and management, who are responsible for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of our products. Credible information regarding a potential violation of any of our policies and standards, whether discovered by the Company, our employees and agents, or suppliers, and their employees and agents, should be promptly reported to our Human Resources Department or Legal Department. The Company prohibits retaliation against anyone who reports a concern in good faith.
Assessing our Effectiveness
Because we have seen no evidence of forced labor or child labor, we did not have occasion to implement any remediation or rectification measures in the 2023 fiscal year. While we believe in our measures to prevent and mitigate forced labor and child labor within our operations and supply chain, we will strive to maintain and continually improve our sustainable and transparent supply chain, and work to maintain an understanding of our global supply chain networks.
Report Approval and Attestation
In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.
I have the authority to bind Rite-Hite International, Inc.
/s/ Antonio P. Catalano
Antonio P. Catalano
Chief Legal & Compliance Officer, Secretary
May 31, 2024