Verification:   Franz relies on documentation from our Approved Suppliers to verify that they do not engage in human trafficking or slavery to acquire the products they provide to us.   Approved Suppliers are subject to unannounced on-site inspections by Franz management personnel at any time to confirm what has been documented.   The vast majority of our suppliers are in the United States so are subject to Federal, State, and Local regulatory requirements prohibiting human trafficking or slavery.

Audit: On site audits of Approved Suppliers are conducted periodically to evaluate compliance with Franz standards against human trafficking and slavery in our supply chain.   Audits are conducted by Franz management personnel and may be unannounced or by appointment.   Approved Suppliers would be selected randomly or specifically chosen if there was a question regarding their compliance with Franz standards. Each year a number of suppliers are reviewed for compliance and on site audits are scheduled if deemed necessary.

Certification: Franz does not require formal certification from our Approved Suppliers regarding standards against human trafficking and slavery. We do require compliance with labor laws of the countries in which they do business which mirrors our own standards.   If Franz has reason to believe that one of our Approved Suppliers is in violation of labor laws or other relevant regulations, we would encourage them to correct the violation or risk being suspended as an Approved Supplier for Franz.

Internal Accountability: Franz employees are either union employees or governed by the same standards as union employees regarding fair labor requirements and especially concerning grievances and reported violations. Compliance with union regulations is monitored by the Human Resources department at corporate level and in each division. Employees are encouraged to address issues of labor laws within the company or as observed during interactions with outside contractors.   Employee communication with immediate supervisors or middle to upper levels of management is encouraged for any concern.

Training: Franz conducts orientation training for all new employees regarding company code of conduct and standards.   Annual review training is conducted for all employees on their role in monitoring company standards.   The expectation is that any concern the employee has regarding company issues internally or interactions with contractors be shared with their immediate supervisor or other management personnel.   This includes violations of labor laws or human trafficking and slavery.