HUMAN RIGHTS POLICY

Respect for human rights and an ardent commitment to sustainable business practices are central to the DNA of WD Advanced Materials, LLC ("WDAM"). From our mission statement, to our corporate brand promise, and our internal and external commitments, we strive to set the standard for integrity within our industry and beyond.

Our Corporate Brand Promise

WDAM defined a comprehensive Code of Ethics & Business Principles that supports our ongoing business practices and is critical to our success in achieving our mission and fulfilling our commitment to operating openly, ethically, and honestly. This charter includes our brand promise, behavior, and core values, as well as measures we collectively take to ensure the health and safety of our employees, company, community, and business partners.

Our Commitment

WDAM aligns our principals, policies, and Code of Ethics to our belief and commitment to doing the right thing. We are committed to the respectful treatment of all individuals as outlined in several United Nations’ Human Rights initiatives which include the Universal Declaration of Human Rights (UDHR), the UN Convention on the Elimination of All Forms of Discrimination Against Women, and the UN Disability Inclusion Strategy, as some examples, and remains committed to paying fair wages, supporting the rights of all workers to be free from discrimination, valuing diversity and inclusion, and ensuring that we have diligence mechanisms in place to hold ourselves accountable.

WDAM provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, genetic information, marital status, amnesty or status as a covered veteran in accordance with applicable federal, state and local laws. Equal opportunity and the protection of human rights extends to all aspects of the employment relationship, including hiring, transfers, promotions, training, terminations, working conditions, compensation, benefits, and other terms and conditions of employment.

It is the intent of this policy to comply with applicable state, local, and federal laws prohibiting discrimination on the basis of color, race, religion, sex, national origin, or any other "protected category" under local, state, or federal law. Our policies and practices support employees’ rights and their access to due process, protected conduct, and/ or communications relating to employee wages, hours or working conditions, or any other conduct protected by Section 7 of the National Labor Relations Act.

WDAM expressly prohibits any form of unlawful employee discrimination, or harassment based on race, color, religion, gender, sexual orientation, national origin, age, genetic information, disability, veteran status or any other category protected under state, local, or federal law.

Our Diligence Processes

WDAM's Leadership Team takes these commitments to ethics, anti-corruption standards, and the protection of human rights seriously and has therefore established the following due diligence mechanisms to support our policies:

We communicate our expectations openly and transparently with our employees, contractors, suppliers, and customers and reinforce our mission, vision, and values in all that we do
Our third-party partners and suppliers must share our commitment to ethical business practices, qualifying through a rigorous application process
We provide an avenue for anonymous or direct reporting – ensuring we will fairly respond and address any reports, while providing an environment that will not tolerate retaliation for doing the right thing; our Grievance Mechanism Form can be found here
We will conduct periodic self-assessments and commit to redress and remediate findings in a fair and timely manner
Our commitment to Human Rights and sustainable business practices is inherent in our communication with relevant business parties, partners, customers and consumers,
We commit to Leadership and Board level review of our performance and in self-assessments, and vow to take recommended actions to address stakeholder feedback.

To support these policies, WDAM developed a Four Step Due Diligence Process that is a reflection of our Code of Ethics & Business Principles, and supported by extensive supplier and customer vetting policies. These processes are in place to assure our business relationships are compliant in relation to anti-corruption policies and the protection of human rights in our labor practices, while ensuring that we do business with vendors and customers that do the same. A comprehensive risk-based review occurs across the areas of finance, supply chain, procurement, and HR/Safety/Compliance. This risk-based assessment, based on severity, scope, and responsibility of the company, will drive the depth and frequency of the process needed in each area. The standards are imbedded in these processes in some areas and happen in the day-to-day ways of working in others.

Our Values in Action

The trust earned through our employees, partners, and consumers is owed to our longstanding ethical business practices, and our open and transparent operations. If for any reason you feel that we are not abiding by our Human Rights Policy, please utilize our Grievance Mechanism Form, accessible via our footer or be clicking here.