Declaration of Principles Regarding Supply Chain Due Diligence

January 2024


Over the course of more than 160 years, JM has built a tradition of financial, environmental, and community stewardship. This tradition, in addition to growing internal and external expectations regarding corporate responsibility, is at the heart of our efforts to act with integrity and be mindful of the impact of our actions on our employees, customers, communities, environment, and reputation. That is why we are committed to respecting human rights and protecting the environment in our own business operations and throughout our supply chain. Accordingly, and pursuant to supply chain due diligence (SCDD) laws like the German Supply Chain Duty of Care Act (Lieferkettensorgfaltspflichtengesetz, or LkSG) and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, Johns Manville has developed this Declaration of Principles to articulate our commitment to complying with applicable human rights and environmental due diligence obligations; our expectation that business partners likewise comply with such laws; and our approach to managing related risks in our business and with our business partners.

Guiding Principles

Johns Manville’s approach to managing human rights and environmental risks is guided by the following internationally recognized human rights and environmental standards and frameworks:

  • United Nations Guiding Principles on Business and Human Rights
  • United Nations Global Compact
  • United Nations Universal Declaration of Human Rights
  • Conventions and recommendations of the International Labor Organization’s core standards on forced labor, child labor, freedom of association, and nondiscrimination on labor and social standards

We also support enacted and pending laws aimed at preventing and eliminating slavery and human trafficking from global supply chains by increasing transparency, including California’s Transparency in Supply Chains Act, the United States’ Uyghur Forced Labor Prevention Act, Australia’s Modern Slavery Act, the United Kingdom’s Modern Slavery Act, the European Union’s draft regulation on forced labor; and the European Union’s proposed Corporate Sustainability Due Diligence Directive.


This Declaration of Principles applies to all Johns Manville employees and operations globally. Johns Manville expects all employees to play an active role in conducting business in a socially and environmentally responsible manner. Johns Manville also expects our suppliers and other business partners to similarly conduct business ethically and responsibly, consistent with the spirit and intent of this Declaration of Principles. Our direct suppliers are thus expected to comply with applicable law – including those regarding human rights and environmental concerns such as the LkSG, implement appropriate supply chain due diligence procedures, and convey these same expectations to their own business partners.

Expectations and Requirements for Employees and Business Partners

To help ensure employees operate in a manner that is not only legally compliant but also ethically, socially, and environmentally responsible, Johns Manville has developed and implemented numerous policies and related documents. The Johns Manville Code of Conduct is particularly relevant; it serves as our foundation and provides guidance on handling legal and ethical situations that may arise in the course of our work on a range of topics including labor and employment rights, environmental laws and sustainability, regulatory requirements, and good governance. We regularly communicate to employees through guidance and training the need to promptly identify, and to the greatest extent possible, eliminate or avoid social and environmental violations. Supplemental training and procedures are provided to employees with relevant responsibilities, such as those in Procurement and Logistics.

As for our vendors, Johns Manville’s Supplier Code of Conduct sets forth the principles, values, and legal requirements that apply to all our relevant business partners. These partners must either agree to comply with our Supplier Code or certify that they maintain and comply with their own business code of conduct, and that their code has the same requirements in principle, to work with Johns Manville. 

Risk Identification and Mitigation

At least once a year, Johns Manville will conduct a risk-based assessment of its own operations and those of its suppliers to identify potential risks of contributing to or being complicit in human rights or environmental violations. To this end, Johns Manville conducts interviews and collects information from its business partners, considering their respective locations and products or services provided. Due to the nature of our operations and the products/services we procure, Johns Manville considers the following types of risks to be the most relevant in our value chain:

  • Health and safety risks
  • Environmental risks
  • Risks of discrimination

Identified risks are prioritized based on the impact, severity, and likelihood of occurrence, and Johns Manville will take appropriate measures to minimize such risks. For example, we may implement or require a business party to implement a risk mitigation strategy or action plan; alternatively, we may conduct a human rights audit. Johns Manville strives to work collaboratively with any business partners who pose a risk, supporting improvements in their policies or procedures. Johns Manville also offers all business partners information material relating to social and environmental due diligence obligations along the supply chain, and we encourage our suppliers to relay our expectations and promote legal, ethical, and responsible practices throughout the entire supply chain.

Grievance Mechanism

We encourage our employees to ask questions and report complaints or concerns to their managers, Legal and Compliance, HR, or the Berkshire Hathaway Ethics and Compliance Hotline (the Hotline). The Hotline is also available to employees of our business partners. The Hotline is administered by a third party and has a specific tier for reporting alleged human rights and environmental violations. Additional information about the Hotline can be found here.

Oversight and Accountability

Johns Manville has designated the Senior Global Compliance Counsel as its human rights officer, who is responsible for monitoring the implementation of and compliance with this Declaration of Principles. She can be reached at

Senior Management is responsible for ensuring compliance with applicable SCDD laws and receives reports no less than annually on the status of the SCDD program.

Our employees and business partners are expected to respect essential human and environmental rights and promptly report any suspected or actual violations.

Continuous Improvement

As PEOPLE champions who PROTECT today to ensure tomorrow, Johns Manville strives for continuous improvement in all areas of its operations. Accordingly, Johns Manville shall regularly evaluate the effectiveness of its risk management framework, prevention and remediation measures, and grievance procedures to ensure the efficacy of its SCDD program. Johns Manville shall also report annually on both the risks identified and the resulting preventive and corrective measures.

Bob Wamboldt,
President & CEO