2023 REPORT UNDER THE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT
2023 Report – Introduction
This report has been prepared by Firestone Airide, a division of Firestone Industrial Products Company, LLC ("FSA"), a wholly owned subsidiary of Bridgestone Americas, Inc. ("BSA"), in response to the reporting requirements under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act") for our financial year ending December 31, 2023.
FSA is committed to respecting human rights and to working collaboratively with stakeholders, including affected and potentially affected groups, to address and remedy adverse impacts from its operations, products or services. The Global Human Rights Policy guides FSA as it commits to respect and support the UN Guiding Principles for Business and Human Rights as well as the human rights set out in the International Bill of Human Rights and the International Labor Organization's Declaration on Fundamental Principles, OECD Guidelines for Multinational Enterprises and Rights at Work. We also expect our business partners, including suppliers, contractors, vendors and customers, to uphold these principles.
Organizational structure, activities, and supply chain
Structure
As mentioned, FSA is a wholly owned subsidiary of BSA and an air spring manufacturer, distributor, and mobility solutions provider globally. BSA is a wholly owned subsidiary of the Bridgestone Corporation ("BSJ"), a Japanese publicly traded company, and a global manufacturer of tires and rubber products. FSA, BSA and BSJ along with their affiliates are herein collectively referred to as the "Bridgestone Group".The Bridgestone Group employs approximately 130,000 people globally and conducts business in more than 150 countries and territories worldwide. FSA employs approximately 1500 employees globally. FSA's headquarters are located in Nashville, Tennessee in the United States.
Activities
FSA manufactures air springs that it sells to affiliates globally, including in Canada. It also distributes air springs globally, through independent dealers. FSA is focused on wholesale and original equipment markets, supplying vibration reducing solutions to passenger, light truck, commercial vehicle, off road, agricultural and rail. Specifically in Canada, our air springs are used mostly in commercial and aftermarket applications FSA both manufactures and sources components used in air springs globally. Raw materials used in air spring manufacturing are sourced from a global supply base.
Steps to prevent and reduce the risks of forced labour and child labour in the importation of goods into Canada by Firestone Airide
The Bridgestone Group conducted a Human Rights Risk Assessment Survey at 100% of its operational facilities and there were no material risks identified from this process. The Bridgestone Group developed an Implementation Guideline for the Global Human Rights Policy to ensure concrete actions are taken to further strengthen its human rights management system and that the system is embedded in the day-to-day operations at its sites. This guideline was distributed to 100 % of the Bridgestone Group's operational sites in 2023. More information can be found here. Other steps include:
• Commencing mapping of activities and supply chains and risk of forced and/or child labour associated with them.
• Conducting an internal assessment of risks of forced labour and/or child labour in the Bridgestone Group's activities.
• Gather information on employee recruitment and maintaining internal controls to ensure that all employees are recruited voluntarily.
• Addressing practices in the Bridgestone Group's activities that increase the risk of forced labour and/or child labour
• Developing and implementing due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in the Bridgestone Group's activities and supply chains.
• Carrying out a prioritization exercise to focus due diligence efforts on the most severe risks of forced and child labour in the Bridgestone Group's activities.
• Requiring suppliers to have in place policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains.
• Developing and implementing anti-forced labour and/or -child labour contractual clauses.
• Developing and implementing grievance mechanisms.
• Developing and implementing training and awareness materials and on forced labour and/or child labour.
The Bridgestone Group has implemented a Global Sustainable Procurement Policy which is distributed to all suppliers, who are required to sign the policy receipt acknowledgement. The Bridgestone Group uses a third-party platform that supports the management of ESG risks and compliance of its tier 1 vendors. The Global Sustainable Procurement Policy can be found here.
Together with other stakeholders, the Bridgestone Group and other tire companies launched the Global Platform for Sustainable Natural Rubber ("GPSNR") in 2018. The Global Platform for Sustainable Natural Rubber - GPSNR is an international, multistakeholder, voluntary membership organization, with a mission to lead improvements in the socioeconomic and environmental performance of the natural rubber value chain. At GPSNR Bridgestone, along with other stakeholders like, smallholders, academia, and civil society, is committed to transform the natural rubber supply chain into a sustainable, equitable and fair one by harmonizing standards to improve respect for human rights, prevent land-grabbing and deforestation, protect biodiversity and water resources, improve yields and increase supply chain transparency and traceability. More information about GPSNR here.
Policies and Due diligence processes
Policies
The Bridgestone Group has confirmed its commitment to respecting human rights and advancing responsible labour practices throughout its global operations in its Global Human Rights Policy. The Global Human Rights Policy can be viewed here. The policy, which applies to all Bridgestone Group employees and locations, affirms the following:
1. Respect for Diversity, Equity and Inclusion
2. Prohibition of Discrimination and Harassment
3. Focus on Workplace Safety and Health
4. Commitment to Responsible Labour Practices, including prohibiting child labour, forced/compulsory labour, human trafficking and modern slavery in our organization and in our supply chain
5. Protection of Freedom of Association and Collective Bargaining
Due Diligence.
The Bridgestone Group has embedded responsible business conduct into its policies and due diligence processes, which include the topics of forced and/or child labour. The Bridgestone Group strives to uphold human rights principles in all that it does, and take proactive steps to ensure employee, customer and supplier experience is consistent with international human rights standards. The Bridgestone Group incorporates human rights initiatives into our business models and across our value chains, priorities, management policies and business strategies. These proactive steps include regularly training our employees and suppliers on our human rights policies/standards, completing annual due diligence activities for our operational sites and suppliers in partnership with third-party experts, and providing our employees, customers, and suppliers with access to grievance reporting systems to raise any concerns. These proactive measures also allow us to minimize the risk of any human rights impacts from our operations and supply chain, and ensure any potential issues are identified quickly and remediated collaboratively with our stakeholders.
Forced labour and child labour risk
Forced labour and child labour risks in our industry may arise due to:
• the nature of the industry
• the types of products produced, sold and/or imported
• the locations of activities
• raw material source used in our supply chains
As mentioned above, the Bridgestone Group distributed an Implementation Guideline to further strengthen its human rights management system and it was distributed to 100% of the Bridgestone Group's operational sites in 2023. The Guideline focused on the prevention of child labor and forced labour and will evolve in tandem with the Group's human rights due diligence processes and advancement of the internationally recognized human rights principles.
Remediation measures and remediation of loss of income
We have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labourin our activities and supply chains
Employee training
The Bridgestone Group has confirmed its commitment to respecting human rights andadvancing responsible labour practices throughout its global operations in its Global Policy on Human Rights. The policy which applies to all Bridgestone employees and locations, affirms the company’s:
1. Respect for Diversity, Equity and Inclusion
2. Prohibition of Discriminationand Harassment
3. Focus on Workplace Safety and Health
4. Commitment to Responsible Labour Practices
5. Protection of Freedom of Association and Collective Bargaining
Bridgestone Group also has the Bridgestone Code of Conduct (“Code”). "The Code was developed with Bridgestone's Mission and the company's other foundational documents inmind. It is intended to provide practical guidance for handling many ethical issues. The Code sets out the Bridgestone Group’s expectations in relation to promoting respect and dignity, diversity, human rights, health and safety and prohibition of workplace violence. The rules andexpectations set forth in the Code not only apply to all Bridgestone Group employees worldwide, they also serve as a set of expectations for the suppliers and contractors who work with the Bridgestone Group. FSA employees completed an online training module on the Global Code of Conduct in 2023. Additionally, a separate online training module on the Global Human Rights Policy was also conducted to further raise awareness. Both training modules were mandatory, and FSA participated in the process.
Assessing effectiveness
The Bridgestone Group has implemented a robust due diligence process for the natural rubber supply chain, including remediation:
1.) Traceability Enhancement of Natural Rubber Supply chain
2.) Risk Assessment conducted in collaboration with 3rd party risk evaluation bodies
3.) Remediation of Risks together with our suppliers
The foregoing includes providing support for Natural Rubber processing factories and Capacity Building for smallholders (enhancement on Quality, Traceability and Sustainability). The Bridgestone Group is committed to continually working toward a more sustainable society to realize long-term environmental, social, and economic benefits across our entire supply chain.
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 Firestone Airide.
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 Firestone Industrial Products Company, LLC.
