Forced / Child Labour

Policy on Compliance and Business Ethics

PURPOSE

To outline DYNA-MIG’S position on Compliance and Business Ethics. 

SCOPE 

All Associates 

MOTTO 

We, the associates of DYNA-MIG, take part in a community sharing a common destiny. We will continue creating new values in good faith, making contributions to the nation and the public in order to build a bright future for everyone. 

MANAGEMENT POLICY 

  • We consider the harmony and integrity of all associates as our basic values. 
  • We will pursue theory and action as one. 
  • We will maintain youthfulness with new ideas and new ways of thinking in our daily work. 
  • We will create values with excellent quality. 
  • We will respect harmonious relationships with the local community.

DYNA-MIG PRINCIPLES

  • Prompt actions 
  • Close communication 
  • Working with a strong sense of responsibility 
  • Candid discussions 
  • Clean and orderly working environment 

POLICY 

CODE OF CONDUCT 

We will always give top priority to ethically appropriate actions in all our activities. We will always comply with the laws of Canada and Ontario, ordinances, and rules, and each of us acts with common sense as a responsible member of society. We have and continue to maintain our reputation as an excellent law-abiding corporate citizen. We respect and follow all laws regarding human rights as outlined by the Ontario Human Rights Code, freedom of associate, the right to be free of harassment and discrimination, the Ontario Employment Standards Act in regards to wage and benefits, working hours, age of employment and our adherence against child labour and the modern slavery in the practice of servitude, mandatory labour and human trafficking. 

DYNA-MIG regulations and rules have been established for ensuring a working environment in which all associates can work together with equal rights and opportunities free from discrimination based on: Age, Ancestry, colour, race, Citizenship, Ethnic origin, Place of origin, Creed, Disability, Family status, Marital status(including single status), Gender identity, gender expression, Receipt of public assistance(in housing only), Record of offences(in employment only), Sex(including pregnancy and breastfeeding), Sexual orientation. 

As associates engage in the production of automotive parts, we are always in compliance with traffic rules and always strive for safe driving. 

Based on an understanding that the Earth is an invaluable asset to humankind, we strive to minimize and ensure disposal or treatment for any waste related to manufacturing and to utilize natural resources and energy in more efficient ways. 

With an understanding that the continued survival of DYNA-MIG relies on the creation of values we strive to raise the corporate value as a company winning recognition from the general public, trying to continue securing profit on a long-term basis. 

We make clear the distinctions between private or confidential information and the information to be disclosed to the public. We strive to provide accurate information that is useful to our customers. 

We do not engage in any unreasonable or irrational business practices. We do not provide benefits or preferential treatment to anyone beyond common sense or generally accepted ideas. We evaluate various conditions based on comparisons in an impartial manner and conduct business transactions that are sound and fair. 

NO RETALIATION 

No retaliation will be permitted against anyone who either reports a concern in good faith or who participates in an investigation of misconduct. Contact the Kaizen Proposal Window if you believe you have been retaliated against. 

RESPECT FOR THE INDIVIDUAL / NON-HARASSMENT

DYNA-MIG demonstrates respect by providing equal employment opportunities for all associates. The Company will not tolerate workplace discrimination, harassment, violence, or retaliation. Harassment has no place at the Company. It does not matter if you are; an associate, a supplier, a contractor, or a temporary, harassment violates one’s belief in “Respect for the individual”. Please review to the Violence and Harassment Policy. 

ALCOHOL AND DRUG FREE ENVIRONMENT

DYNA-MIG believes in a work environment free of alcohol and drugs. A business-like atmosphere cannot be maintained without prohibiting the influence, possession, or consumption of these items on Company premises.

SAFE AND HEALTHY WORK ENVIRONMENT

DYNA-MIG is committed to provide a safe and healthy work environment. Each of us has an obligation to every other associate to ensure safe conditions throughout each day. This means you need to participate in safety training, follow safety standards and policies and make safety a priority in everything you do. 

COMPENSATION 

DYNA-MIG is committed to paying associates fairly, in compliance with relevant laws, and to record all the time worked accurately and honestly. Managers are responsible for ensuring that associates receive appropriate compensation for all time spent working for DYNA-MIG. 

COMPANY RULES AND POLICIES

DYNA-MIG has rules and policies that establish boundaries for decision making. We will obey these rules and policies, and participate in creating, changing, or eliminating them by speaking up and doing our best to influence change and progress. However, as long as a policy or rule exists, we have the responsibility to comply with it. 

CONFLICTS OF INTEREST 

Building strong relationships with suppliers is an important part of how we do business. We treat our suppliers fairly. Make decisions based on sound business reasons such as suitability, quality, delivery and cost. 

Those activities, interests or relationships that affect or appear to affect the impartiality, judgement, or effectiveness of associates in the performance of their jobs conflict with company interests. Please refer to the Conflict-of-Interest Policy. 

COMPANY ASSETS 

Take care of DYNA-MIG assets as if they were your own. Use them solely for Company business or for purposes authorized by management. Theft, fraud and other misuse of DYNA-MIG assets are prohibited. 

INTERNET AND E-MAIL COMMUNICATIONS

DYNA-MIG computer network is available for the exclusive use of active associates. From time-to-time DYNA-MIG may review files and communications to maintain system integrity and ensure that users are using the system in a responsible manner. Associates must not engage in Internet chat rooms, online games, and sites which contain what could be deemed offensive material. Also, must not engage in the communication of said material to other associates.

GOVERNMENT REQUESTS AND INVESTIGATIONS 

All inquiries from a government agency regarding DYNA-MIG, or another F.Tech group affiliated company are to be referred to the HR Department. 

MEDIA REQUESTS 

Due to the confidential nature of our business, the Company prefers to stay out of the media limelight. All inquiries from the media regarding the Company need to be promptly referred to DYNA-MIG’S HR Department. Inquiries that may come to the Company regarding another F-tech Group affiliated company must be promptly referred to DYNA-MIG’S HR Department. 

LITIGATION

DYNA-MIG may sometimes be involved in disputes that may result in claims or litigation. If you receive a legal document related to the company, contact the HR Department immediately to ensure an appropriate and timely legal response. Under no circumstance should you threaten or initiate legal action on behalf of DYNA-MIG without the prior advice and approval of the Board of Directors. 

PRODUCT SAFETY AND QUALITY 

Our reputation is based on the safety and quality of all our products. We aim to exceed our customer’s expectations by putting quality in everything we do. Let management know of any product not meeting the company’s quality standards. Never attempt to conceal substandard work or products. 

COMMUNITY RESPONSIBILITY 

DYNA-MIG is a good corporate citizen by supporting community activities such as sponsorship and donations.

ENVIRONMENTAL PROTECTION 

Protecting the environment is an obligation we all share. All associates are expected to comply with all procedures for proper handling and transporting of hazardous substances and to minimize waste through recycling, reuse and pollution prevention. 

FAIR COMPETITION (COMPETITION AND ANTITRUST) 

DYNA-MIG supports both free and open competition. We strive to provide innovative technology, products, and services at a reasonable cost in a highly competitive industry. Antitrust and competition laws in the United States and Canada promote competition, and DYNA-MIG fully complies with these laws. Some examples of behavior prohibited by these laws include; agreeing with competitors to limit production, fix prices, or divide markets, customers, or territories. 

POLITICAL ACTIVITIES

DYNA-MIG encourages associates to exercise their right to vote and participate in the political process. If you are involved, please be sure that you express your views as an individual, not as a representative of DYNA-MIG. Any political activities must be on your own time and at your own expense. 

INTERNATIONAL BUSINESS AND TRADE

EXPORTS

Most countries have laws that control the import and export of goods and technology, which may require export licenses. Ensure you provide the shipping with accurate paperwork describing the product, the product’s value, the country of origin of the product and other information that may be needed. Consult with your local trade compliance group for more information on shipping requirements.

IMPORTS 

Duty must be paid on most imports. The amount of duty is determined by the item’s tariff classification. If you have ordered an item that is to be imported, a broker or local trade compliance group may contact you for more details on the item. All information you or our agents provide to government officials or agencies is to be accurate and truthful. 

Never hand-carry DYNA-MIG parts or equipment from one country to another with preparing the proper paperwork and declaring the items to customers. 

BUSINESS DEALING IN FOREIGN COUNTRIES

DYNA-MIG conducts itself ethically everywhere we do business. You may not make payments to agents or other representatives of the Company if you have reason to believe that these payments may result in bribes to foreign officials. All associates also abide by local anti-corruption laws in any country in which we do business. 

REPORTING SUSPECTED VIOLATIONS 

Report suspected violations of this Policy to any of the following: 

  • Your supervisor
  • The Kaizen Proposal Window
  • The Corporate Ethics Officer

In reporting potential violations, please include the following information: 

  • The Department/Shift 
  • The nature of possible violation (such as safety or harassment) 

REMEMBER: 

You do not need to be certain a violation has occurred to report it, but you should have heard or seen something yourself or have other good evidence that a violation has occurred. 

  • All reports are confidential. You may remain anonymous. 
  • To allow a full investigation, provide as much information as possible. 

SUMMARY AND UTILIZATION OF POLICY

SUMMARY OF BUSINESS ETHICS 

No associate of the Company should do anything that in his/her personal opinion is unethical. Ethics are not always black and white issues and require individual judgement. If confronted with an issue, ask yourself the following questions:

1. Is it legal?
2. How would I feel if my family or friends know of my action?
3. How would I feel if it was disclosed to the media?

We see ourselves as ethically sound people and strive to maintain our reputation as a Company of high principles and values. We continue to be a Company that tolerates nothing less than complete honesty, integrity, and fairness in everything we do.  

UTILIZATION OF THE POLICY

For the purpose of this policy, the Compliance and Ethics Officer / Kaizen Proposal Window is Kiyoshi Horiuchi. His role is to oversee the corporate compliance and Ethics Policy and Guidelines. In his/her absence, Diane McMahon will conduct investigations of alleged violation of, or questions under the Company Compliance and Ethics Policy. 

Human Rights and Labour Policy

PURPOSE:

Through the implementation of this policy, we will work together with our stakeholders to engage in sustainable business activities in order to continue to be a company that is socially responsible.

This policy is disclosed on the DYNA-MIG website and is communicated to all stakeholders.

SCOPE:

This policy applies to all Associates (including temporary and contract Associates). DYNA-MIG also expects all business partners to understand and support the contents of this policy and requests to comply with it.

POLICY:

COMMITMENT TO RESPECT HUMAN RIGHTS

DYNA-MIG recognizes that its business activities may affect the human rights of various internal and external stakeholders.

DYNA-MIG respects human rights as expressed in the International Bill of Human Rights and the ILO Core Labour Standards listed in the Declaration on Fundamental Principles and Rights at Work. We also support the United Nations Guiding Principles on Business and Human Rights and work toward implementation in our business activities.

DYNA-MIG shall comply with the laws and regulations of each country and region in which it operates. However, in cases where there is a conflict between the laws and regulations of each country or region and international human rights principles, we will seek to respect international human rights principles.

GOVERNANCE

DYNA-MIG has established respect for human rights as an important management issue and will clarify the individuals responsible for formulating and implementing this policy. We will also establish an appropriate internal system, and reflect the policy in its business policies and procedures.

RESPECT FOR HUMAN RIGHTS:

DYNA-MIG recognizes the following as key issues related to human rights, and will promote initiatives to respect human rights. We will continuously review the policy as human rights risks may change with business development and business trends.

  1. Prohibition of discrimination and harassment

We will not engage in discrimination or harassment based on race, nationality, place of origin, gender, age, religion, creed, sexual orientation, gender identity, or disability.

  1. Prohibition of forced labour and child labour

We do not permit any form of forced or compulsory labor or the employment of children under the minimum age for employment as stipulated by the laws of each country or region. We will continue to meet the legislated requirements of Fighting Against Forced Labour and Child Labour in Supply Chains Act.

  1. Respect for workers’ rights

We will respect workers’ rights to organize, bargain collectively, and act collectively, and will prevent low-wage labor and long working hours.

  1. Creation of a safe and healthy working environment

We will strive to maintain a safe and healthy working environment and promote the maintenance and improvement of the physical and mental health of our employees.

  1. Sharing human rights with business partners

We will share with our business partners our concern for human rights, labor, the environment, and anti-corruption, and engage in ongoing discussion regarding respect for human rights.

PRACTICE OF RESPECT FOR HUMAN RIGHTS

  1. Human Rights Due Diligence

In order to fulfill its responsibility to respect human rights, DYNA-MIG will establish a human rights due diligence system in accordance with procedures based on the United Nations Guiding Principles on Business and Human Rights, and shall continuously strive to prevent or mitigate negative impacts on human rights.

  1. Remedies and Corrections

When it becomes clear that DYNA-MIG has directly or indirectly caused or contributed to a negative impact on human rights, DYNA-MIG shall work to remedy the situation. As part of these efforts, the F-tech Group has established “F-tech Group Corporate Ethics Improvement Proposal Desk,” which all directors and employees can consult with and report to, as well as “Contact Us” page on the F-tech Group’s website will also allow stakeholders to report such matters.

  1. Education and Training

DYNA-MIG conducts appropriate education and training for all Associates to ensure that the policy is properly understood and implemented.

  1. Communication and Consultation with Stakeholders

DYNA-MIG will consult with outside experts and engage in communicating and consulting with relevant stakeholders regarding implementation of this policy.

  1. Information Disclosure

DYNA-MIG shall disclose information on its efforts to respect human rights through its website and other means including meeting the requirements of Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Forced Labour In Canadian Supply Chains Annual Report