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Conflict Minerals Policy

This document contains H.B. Fuller’s statement regarding the use of conflict minerals in our products. As used in this policy, “H.B. Fuller” includes H.B. Fuller Company and its majority-owned subsidiaries, as applicable, unless otherwise noted.

Regulatory Background

On August 22nd, 2012, the United States Securities and Exchange Commission (the “SEC”) adopted a final rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Conflict Minerals Rule”). The Conflict Minerals Rule is intended to reduce a significant source of funding for armed groups that are committing human rights abuses in the Democratic Republic of Congo (the “DRC”) and its adjoining countries.

Under the Conflict Minerals Rule, to the extent that “conflict minerals” are necessary to the functionality or production of products that H.B. Fuller manufactures or contracts to manufacture (the “Covered Products”), the SEC requires H.B. Fuller to conduct supply chain due diligence to determine whether the conflict minerals originated in the DRC or one of its adjoining countries. The DRC and its adjoining countries are collectively referred to under the rule as “covered countries.” In addition to the DRC, the covered countries include: Angola; Burundi; Central African Republic; the Republic of the Congo; Rwanda; South Sudan; Tanzania; Uganda; and Zambia. The minerals (and derivative metals) covered by the Conflict Mineral Rule include: Cassiterite (Tin); Columbite-tantalite (Tantalum); Wolframite (Tungsten); and Gold. The Conflict Minerals Rule defines these minerals (sometimes referred to as “three Ts and gold” or “3TG”) as “conflict minerals,” regardless of their country of origin.

Publicly traded companies must report annually to the SEC the presence of conflict minerals originating in the DRC and its adjoining countries in products that they manufacture or contract to manufacture if those conflict minerals are necessary to the functionality or production of the products.

H.B. Fuller’s Policy with regard to the Conflict Minerals Rule

H.B. Fuller Company is committed to ethical practices and compliance with applicable laws and regulations, including SEC regulations and the Conflict Minerals Rule. As a public company that manufactures or contracts to manufacture products that may contain conflict minerals, H.B. Fuller is working with its suppliers to determine whether the conflict minerals in its products originated from a covered country and if so, to determine if it is a source of funding for armed groups. We recognize that there may be multiple layers in the supply chain between our suppliers and the smelter of the conflict minerals that are in or may be in the goods that are supplied. Most of our products are not Covered Products, but for the small number that are, we do not generally source conflict minerals directly from the source of supply (mines, smelters, refiners). Therefore, we are generally removed by several levels from the ultimate source of conflict minerals. Because of this, we will use reasonable due diligence to identify the source of the conflict minerals, realizing that this will require the cooperation of our suppliers to meet our compliance obligations.

H.B. Fuller does not knowingly support any action which provides funding, or any form of support, for armed groups that are committing human rights abuses in the DRC and its adjoining countries. Our goal is to comply with the Conflict Minerals Rule and continually gain more transparency in our supply chain. We recognize that, due to the complexity of our supply chain, this goal will take time and effort. To comply with the requirements of the Conflict Minerals Rule, we will:

  • understand the Conflict Minerals Rule and its background;
  • communicate and educate our personnel, suppliers and customers regarding the Conflict Minerals Rule and we will urge our suppliers to establish policies to ensure that any conflict minerals used in our products are conflict-free and to comply with this rule and provide all necessary declarations;
  • create processes and procedures to conduct a reasonable level of supply chain due diligence and to comply with applicable SEC reporting requirements; and
  • endeavor efforts to source from conflict-free suppliers.

H.B. Fuller values its supplier and customer relationships. H.B. Fuller is initially focusing most of its efforts on its most significant top-tier suppliers of goods that contain conflict minerals, and over time expects to extend that focus to small suppliers deeper in the supply chain. Suppliers who are materially non-compliant will be reviewed by our sourcing managers for future business.

This policy will be reviewed and revised from time to time, as needed.

Last revised: May 30, 2014



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