Ethics and Compliance
DE LA FONTAINE is committed to protecting the information from users of its website, which is collected, used and communicated if necessary, all in accordance with the requirements of the regulations in force.
Being responsible for the personal information under its control, whether obtained directly or indirectly from customers or third parties, DE LA FONTAINE undertakes by this policy to ensure the confidential and secure treatment of information concerning you. This policy sets out, in general terms, the modalities related to the lifecycle of the information we collect about you when you browse this website.
2. SCOPE
This policy applies only to the use of this site. When agreements are entered into with service providers or agents to obtain information storage, management and processing services, this policy does not apply. However, we require our service agreements to contain information protection and confidentiality provisions comparable to our data protection requirements.
3. EXTERNAL LINKS
This site provides links to other websites. We advise you to read the privacy policy that applies to the websites you visit since the information exchanged by intermediaries that we do not control is not subject to this policy.
4. INFORMATION TRANSMITTED AUTOMATICALLY WHEN ACCESSING OUR WEBSITE
As soon as you access our website, an exchange of information between your computer device and our server takes place without any intervention on your part being required. Without you being personally identified, we bring to your attention that the information exchanged concerns:
- Internet domain name
- Browser type or operating system
- The date and time you access the site
- Pages visited
This exchange of information is necessary for statistical purposes, in order to know the computer technology used by our visitors, the country of origin of our Internet users as well as to count the number of visitors.
Please consult the sections below to learn more about the data transmitted automatically between computers.
5. USE OF COOKIES AND TRACKING TECHNOLOGY
A cookie or is an information file that is placed on your browser by a server when you visit a website. The latter can be retrieved by this server during subsequent visits. Cookies can only be read by the website that transmits them to your computer. These inform us of the computer devices you use as well as your interactions in our Web universe. They are used to facilitate navigation on the pages of this site, to measure our performance, and to compile statistical data.
The Internet user can, at any time, configure his browser to block cookies. However, you should be aware that this action may deprive you of certain functions offered on the website.
The types of cookies used are generally classified into four categories:
- Strictly Necessary Cookies: These are necessary for the website to function normally and cannot be disabled.
- Performance cookies: These are used to count visits and traffic sources to our site. If these are deactivated, we will not be able to know when you visited our website.
- Functionality cookies: If deactivated, these cookies will cause our functionalities to not be optimal, or even faulty.
- Targeting cookies: These are used to aggregate information about your activities on our website and other sites to build a profile of your interests. By deactivating them, you will elude our targeted advertising on other websites.
We also use log files to store, through a server, each of the requests that have been sent to it in order to measure the volume of transactions, always with the aim of improving our website and personalize its content.
6. PERSONAL INFORMATION WE COLLECT
When you voluntarily subscribe to our services, or subscribe to our newsletter, the personal information we may collect about you includes:
- Your first and last name
- Your address and personal details
- Your email address
- Curriculum vitae
- Any information provided voluntarily
- the information necessary for us to offer you our services
7. USE OF PERSONAL INFORMATION COLLECTED
We use the information collected for several purposes, including:
- To personalize the content of our website
- To better understand your needs and offer better services
- To authenticate you
- To better understand digital interactions regarding our business
- To communicate with you
- To open a customer account
- To update, improve and manage our databases and our records, knowledge and precedents management systems
- To generate general profiles of users of our website
This information is not used for any other purpose. In addition, if you choose to send us personal information by email, we will only use the information required to respond to your request.
8. COMMUNICATION
At no time will the information collected about you be made public or sold. In certain circumstances, however, they may be communicated:
- If we have consent to do so;
- In the event that we work jointly with partners for the purpose of promoting our services and evaluating our performance;
- If we need to share your information in order to provide you with the professional services to be rendered (if the provision of the service requires it);
- If the communication is required by law and we must comply with it.
- Communication is limited to what is necessary and appropriate to provide our services to you.
9. ECONOMIC AREA
The principles underlying the regulatory model in force within North America are in particular those of informed consent, collection of data appropriate and adapted to the objectives pursued, confidentiality, right to access and rectification of information.
We assure you that we strive to develop and implement a policy that respects the main principles of data protection, all with a view to aligning the various regulations currently in force around the world.
10. DATA SECURITY
In order to avoid the risk of security incidents related to the various data collected on our website, we have implemented internal measures to ensure information security. We protect personal information in our records and records management system against loss, misuse, unauthorized access and alteration by using secure facilities, password protection, standard security practices and tools and well-defined internal policies and practices. In the event of a security breach, we will make it our duty to limit any potential harm.
11. ACCESS TO YOUR PERSONAL INFORMATION
Customers and users of this website who wish to consult the personal information concerning them and contained in our records can make a request and contact the person in charge of the protection of personal information at the following address to obtain access: sdube@delafontaine.com
This report concerns the fiscal year ending August 31, 2024. It is published by DELAFONTAINE Inc., in compliance with the Act to combat modern slavery and child labor in supply chains (the “Act”) in force in Canada.
References in this report to “DELAFONTAINE,” “Company,” “we,” “us” and similar terms mean DELAFONTAINE Inc.
This report describes our approach to preventing and mitigating risks related to the use of modern slavery or child labor in our operations and supply chains, in addition to providing an overview of some of the initiatives we see in this domain, it being understood that these are scalable.
2. PREVENTION AND MITIGATION OF THE RISKS OF MODERN SLAVERY AND CHILD LABOR
At DELAFONTAINE, we believe in the importance of adopting robust practices to combat modern slavery and child labor in our company and within our supply chains, in particular by promoting fair, ethical working conditions and morality with all of our business partners.
During our last fiscal year, no new measures were put in place to prevent and mitigate risks relating to the use of modern slavery or child labor in our supply chains. However, within the framework of our direct activities, we have continued to adhere to healthy practices regarding working conditions and hiring, particularly with regard to the collection of data concerning the recruitment of workers, which involves verification of the age and criminal records of our employees.
Following the end of the 2024 fiscal year, as part of the Act to combat modern slavery and child labor and as part of our ISO 9001:2015 certification, we have undertaken to review our suppliers’ selection and evaluation processes.
We are determined to continue to strengthen our actions to keep our own operations free of modern slavery and child labor, while requiring the same level of firmness from our suppliers.
3. OUR BUSINESS ACTIVITIES AND SUPPLY CHAINS
DELAFONTAINE is a major manufacturer of steel doors and frames located in Quebec. Thanks to our 245 employees in Sherbrooke and our 150 employees at our American subsidiary, located in 8 faciltiies, we are able to serve a vast territory.
In business for over 55 years, we have carved out a niche in our industry to become a leader in America in the manufacturing of steel doors and frames.
3.1. Our supply chain
We source our merchandise from suppliers located primarily in North America. During our last fiscal year, almost all of our products were purchased in Canada (94.5%) and the United States (5.4%), while a tiny portion came from China (mainly screws and bolts).
We recognize, however, that our direct suppliers themselves have their own supply chains, which are sometimes complex and may extend into foreign countries which may have a greater prevalence of worker rights abuses, particularly in certain countries. from Asia, Europe and South America. This is why we select suppliers with a solid history and good reputation.
We believe that managing social risks in our supply chains is a shared responsibility between us and our suppliers. Indeed, respect for human rights is a collective responsibility that involves all companies, regardless of their location of activity.
4. DUE DILIGENCE POLICIES AND PROCESSES
DELAFONTAINE has no tolerance for modern slavery and child labor. Although we already have a process for selecting and evaluating our suppliers through our ISO9001:2015 certification, we have recently begun a complete review of it so that it becomes an integral part of our internal control process. At the end of this process, suppliers will be evaluated according to several criteria and based on risk to ensure compliance with applicable laws, grant adequate working conditions as well as fair wages to their employees and encourage their own suppliers to be compliant. with applicable laws, including a strict prohibition on the use of modern slavery or child labor.
Regarding our direct activities, we remain committed to maintaining best practices with regard to working conditions and the recruitment process, in particular by paying particular attention to employee recruitment. As such, we conduct a systematic criminal background check on our employees, while providing them with an Employee Handbook, which includes our policies and regulations, with which our members must comply.
This manual encompasses all of our company regulations and policies, including health and safety and workplace behavior. Consequences for any behavior that deviates from company rules and policies may include severe and appropriate administrative or disciplinary measures.
Our staff benefit from a wealth of training relating to workplace health and safety, but to date we have not provided any specific training regarding human rights issues.
Over the next year, we plan to amend our Employee Handbook so that it reflects our commitment to combating modern slavery and child labor. We also aim to carry out a prioritization exercise aimed at focusing our due diligence efforts on the most significant risks that we could identify in our supply chains in terms of modern slavery and child labor.
5. RISK ASSESSMENT
Given that our workforce consists primarily of unionized workers and office staff, we believe the risk of human rights abuses in our direct operations is very low. This risk management is also an integral part of our ISO9001:2015 certification.
6. MANAGEMENT OF IDENTIFIED RISKS AND CORRECTIVE MEASURES TO REMEDY ANY USE OF MODERN SLAVERY
Until now, no corrective measures have been taken by DELAFONTAINE regarding the use of modern slavery, child labor or the loss of income of vulnerable families, given that no specific cases of such violations have been brought to our attention.
7. EVALUATION OF THE EFFECTIVENESS OF OUR APPROACH
We are committed to continuing to improve and correct any gaps in our operations related to the protection of human rights. Our ongoing commitment is to ensure that modern slavery and child labor practices do not find their way into our business and our supply chain.
DELAFONTAINE’s goals for the future include developing effective practices to prevent modern slavery and child labor at all stages of our business operations, including through our internal control measures, by amending our Manual employees and continuing our risk assessment process as well as our prioritization exercise aimed at focusing our efforts on the most significant risks in order to establish appropriate due diligence measures, where applicable.
This report was approved by the board of directors of DELAFONTAINE on August 31, 2024 in accordance with paragraph 11(4)(a) for the fiscal year ending August 31.
In accordance with the requirements of the Act, and in particular section 11 thereof, we certify that the information contained in the report for the entity or entities listed above. To the best of my knowledge, and after having exercised reasonable diligence, I confirm that the information contained in the report is true, accurate and complete in all material respects for the purposes of the Act, for the above-mentioned reporting year.
I am authorized to make contractual decisions for DELAFONTAINE INC.
Gabriel de La Fontaine
General Manager
September 19, 2024