FTJCO Human Rights & Environmental Due Diligence

1. Commitment

FTJCo respects internationally recognized human rights, including environmental rights, and is committed to environmental sustainability in its own operations and supply chains. We conduct ongoing human rights and environmental due diligence and seek to identify, prevent, mitigate, and account for adverse impacts linked to our business.

We recognize the importance of collaborating with suppliers and affected stakeholders to address human rights and environmental challenges. We aim to maintain sustainable purchasing practices that favour long-term business relationships, work toward living incomes and living wages, and provide for or cooperate in the remediation of harms that we cause or contribute to.

This commitment is implemented through FTJCo’s Human Rights page, On the Environment page, Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas, complaints procedure, and periodic risk assessments.

2. Complaints procedure

FTJCo maintains a written procedure for handling complaints of injustice, harm, fraud, or environmental harm linked to the company or its supply chain. Complaints may be submitted by workers, contractors, suppliers, business partners, customers, or other affected individuals and groups.

1. Submission. Complaints may be made in writing or verbally. Written complaints may be submitted through the embedded form below or by email to supplychain@ftjco.com. Verbal complaints may be made by phone or in person and will be documented internally by FTJCo.
2. Acknowledgement. FTJCo will acknowledge receipt within 5 business days where contact details are available.
3. Initial review. A responsible person will review the complaint, assess urgency and confidentiality needs, and identify whether further information is required, normally within 20 business days of receipt.
4. Response and action. FTJCo will determine appropriate follow-up actions, which may include investigation, corrective action, engagement with suppliers, referral to specialist support, or remediation measures. Where possible, FTJCo aims to communicate the proposed next step within 30 business days.
5. Closure. FTJCo will document the outcome and communicate follow-up actions to the relevant parties. Where more time is needed, FTJCo will provide an update on progress.
6. Appeal or escalation. If a complainant believes the matter has not been handled appropriately, they may request a secondary review by senior management or a designated external advisor.

3. Safeguards

• A specific person is responsible for administering the complaints process: One of FTJCo's current CEOs. At the time of writing, these are Robin Gambhir and Kesha Frank.
• FTJCo prohibits retaliation, threats, intimidation, or other harm against any person who raises a complaint in good faith.
• Complaints will be handled confidentially to the extent reasonably possible, with additional care for sensitive matters such as harassment or gender-based violence.
• Anonymous complaints or concerns may be submitted by mail to:
  FTJCo
  576 Parliament Street
  Toronto, Ontario
  Canada M4X 1P8
  Attn: Supply Chain
• All complaints will be documented internally in a complaint log, including date received, issue type, actions taken, and closure date.

5. Risk assessment approach

FTJCo conducts a human rights and environmental risk assessment for its own operations and main supply chains at least every three years. The assessment considers FTJCo’s principal products, main commodities, and relevant sourcing countries, using available external research and internal supply chain knowledge.

• Map common human rights and environmental risks in FTJCo operations and main supply chains.
• Assess which risks are most severe and likely, including salient issues where relevant.
• Identify suppliers or supply chain segments with comparatively higher risks and consider root causes.
• Identify vulnerable groups who may be disproportionately impacted.
• Review FTJCo purchasing or business practices that may cause or contribute to risks.
• Consult staff and immediate suppliers when prioritizing the issues to address first.

6. Supplier engagement

FTJCo seeks to work with suppliers through improvement-oriented engagement and long-term relationships. FTJCo does not use the results of risk assessments to require suppliers to immediately eliminate identified risks as a condition of purchase, but instead works toward appropriate corrective action and responsible remediation where needed.