Report on Measures to Prevent and Reduce the Risk of Forced and Child Labour in Supply Chains
I. INTRODUCTION
This is the first report of Rytec Corporation (“Rytec”) under the Fighting Against Force Labour and Child Labour in Supply Chains Act (the “Act”). This report sets out the information required by Act.
II. RYTEC’s STRUCTURE, ACTIVITIES AND SUPPLY CHAIN
a. Structure and Activities
Rytec is a North American leader in the development, manufacture and sale of high-performance doors. Rytec manufacturers high-cycle, high-speed doors for industrial and commercial applications. We have set out our mission, vision, and values below.
Mission: To provide technology-driven high performance door solutions that efficiently enable safe access to and secure separation from areas and environments.
Vision: A respected industry innovator and leader, trusted and valued by our customers, partners and community.
Core Values: follow our values each day with every interaction you have.
- Accountability: Be responsible to yourself, business partners and the community.
- Respect: Treat others with fairness, professionalism and dignity.
- Commitment: Be dedicated to making a difference through passion, improvement and innovation.
- Integrity: Create trust through honest and ethical interactions.
- Collaboration: Make a personal commitment to promote teamwork and seek mutual gains in your relationships.
Rytec’s headquarters and manufacturing facilities are located in Jackson, Wisconsin and Hartford, Wisconsin. All of our subsidiaries, which includes Winfield Development LLC (which owns the Jackson building), Winfield Development II LLC (which owns the Hartford building), and Rytec IC-DISC (a disregarded entity for tax purposes) are based in the US. As of December 31, 2023, Rytec and its subsidiaries had over 300 employees in the United States and one in Canada.
In 2023 our worldwide sales were roughly $218 million. We sell to and through dealers and contractors, as well as directly to end users. The majority of our sales are based in the US, however, Rytec does sell directly and indirectly in Canada.
Rytec sells various types of high quality, high performance doors; including fabric doors, rigid rolling doors, sliding doors, and related ancillary components. Our products are used in the parking, cold storage, warehousing, automotive retail, and other industries.
Further information on our products and services can be found on our website: https://www.rytecdoors.com/
b. Supply Chain
Rytec’s main purchases are raw materials & configured parts for our doors. We also purchase ancillary services for the installation of our doors.
In 2023, we sourced products from suppliers in Canada (less than 1%), the United States (85%), and Germany (15%). Suppliers from these countries make up a significant majority of our purchases. Notably, we have long-term relationships with two of our suppliers in Germany. The majority of ancillary service install purchase orders are from the US. In this regard, we have a good working knowledge of our first-tier suppliers.
These purchases generally consist of the following goods: crates and packaging,
electrical and safety components, fabric, metals, motors and gearboxes, spiral windows, and
sub-contracted doors synthetics.
III. POLICIES AND PROCEDURES IN RELATION TO FORCED AND CHILD LABOUR
Rytec has a number of internal policies and practices in place for our employees, including our Employee Handbook, which sets out the ethical business conduct principles with which all our employees must comply. The Employee Handbook must be followed by all staff. Other relevant policies we have adopted include policies on Health and Safety and Workplace Violence Prevention, among others.
All of our purchase orders are subject to our terms and conditions, which require compliance with laws. This includes laws which prohibit forced and child labour, as well as import prohibitions for goods made in whole or in part by forced labour. Our terms and conditions are available online here: https://www.rytecdoors.com/purchase-order-terms-conditions.
Rytec has not adopted further policy measures or practices in relation to forced and child labour as we believe, based upon our risk assessment, which includes an assessment of our suppliers, the above measures are commercially reasonable steps given the potential risk.
IV. RISK ASSESSMENT, MANAGEMENT AND MITIGATION
For the activities conducted at our facilities Rytec does not see any risk of forced or child labour. Further, we view the risk of any forced or child labour from our supplier base as low. As noted above, we have a good working knowledge of our first tier suppliers. Given that we source from first tier suppliers that are nearly all based in the United States, Canada, and Germany we believe there is a low risk of forced or child labour stemming directly from those suppliers. Rytec recognizes that its supply chains may have a risk of forced labour and child labour. Risks may be present in our tier three and four suppliers.
V. EFFECTIVENESS OF OUR ACTION
We closely monitor the application and effectiveness of our policies. Amendments and revisions are made to our policies and practices as the need arises.
VI. REMEDIATION MEASURES
We have not identified any incidents of forced or child labour in our supply chains. As such, we have taken no remediation measures. We are committed to taking appropriate remediation measures and assisting vulnerable persons to the extent we become aware of any instances of forced or child labour.
VII. TRAINING
Rytec provides training sessions for all new employees, which include onboarding and familiarization with key policies and practices. We conduct staff training on safety, violence and harassment training as well as on our core values and mission. This is mandatory training and can be done virtually or in person. Training is done on an annual basis. Employees are required to review the employee manual and sign an acknowledgement that they understand the policies.
APPROVAL & ATTESTATION
In accordance with the requirements of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for Rytec Corporation I attest that the report has been approved by the board of directors and that, based on my knowledge and having exercised reasonable diligence, the information in the report is true, accurate and complete in all material respects for the purposes of the Act.
