Transparency in Supply Chains Act

California Transparency in Supply Chains Act

Disclosure Pursuant to the California Transparency in Supply Chains Act of 2010

Trinseo supports the objective of the California Transparency in Supply Chains Act to provide consumers with access to information pertaining to efforts to eradicate human trafficking and slavery from supply chains.

Trinseo’s longstanding Code of Business Conduct (the "Code"), and its supporting Labor and Human Rights Policy, emphasize the importance of complying with all human rights and labor laws and promoting respect and dignity for all workers. These set out expectations that the company’s suppliers embrace similar values and standards.

In April 2015, Trinseo published a comprehensive Supplier Code of Conduct on its public website, provided awareness training to its employees, issued a press release, and conducted mailings to major raw material suppliers. The Supplier Code’s scope includes provisions specifically prohibiting forced, bonded or indentured labor, involuntary prison labor, or any other form of involuntary labor or engaging in human trafficking, amongst other requirements respecting human and workers' rights.

In addition to Trinseo’s direct management of its raw material procurement, the company contracts with The Dow Chemical Company to manage procurement of other products and services. Dow’s California Transparency in Supply Chain Disclosure is posted on its website.

Verification: For raw material purchases, Trinseo’s protocol for verification includes the use of a scorecard process globally for selection and retention of suppliers that has a requirement that the supplier have policies prohibiting human trafficking and slavery. Trinseo does not use a third party monitor to perform verification.

Auditing: Trinseo currently does not audit its raw material suppliers’ efforts to evaluate compliance with company standards for trafficking and slavery in its supply chains. However, it has reserved its right to do so in the Trinseo Supplier Code of Conduct and has also set forth its expectation that suppliers will implement controls. Trinseo is evaluating whether to require audits, whether they will be announced or conducted by a third party.

Certification: Trinseo does not have a certification process that specifically requires suppliers to certify that materials incorporated into its product comply with laws regarding slavery and human trafficking. However, in addition to its scorecard approach, Trinseo contracts generally require that its suppliers comply with all laws and Trinseo standards. Additionally, Trinseo has developed a new template to be used in commercial contracts requiring compliance with its Supplier Code of Conduct, which includes the specific prohibition against slavery and human trafficking. Certification may also be considered in a future phase of the company’s supplier process.

Internal Accountability: Noncompliance with company standards can result in action up to and including dismissal of a company employee, contractor or supplier. The Supplier Code of Conduct, as well as Trinseo’s Code of Business Conduct, encourages suppliers to report any violations of the Code to a confidential ethics hotline. Trinseo’s Chief Compliance Officer ensures that reports of violation are investigated and appropriate corrective/preventative actions are put into place. Trinseo maintains a non-retaliation policy.

Training: Trinseo has provided training to its procurement team on the Supplier Code of Conduct. Trinseo also provided an awareness training session on its Supplier Code to its senior leadership team, Environmental Health and Safety leadership team, and provided an intranet news story available to all employees. This training included the topics of slavery and human trafficking. Trinseo is currently considering developing a more in-depth training and awareness program on human trafficking.

The issuance of Trinseo’s Supplier Code is part of a phased approach and this Disclosure will be updated as significant changes are implemented.

Trinseo UK Limited’s Modern Slavery and Human Trafficking Statement

UK modern slavery act compliance and anti-slavery statement central register

This statement is made pursuant to the UK Modern Slavery Act for the Fiscal Year ending December 31, 2018.

Trinseo is committed to making certain that there is no “modern slavery”, as defined in Section 54 of the UK Modern Slavery Act, in our supply chains or businesses. Our policies reflect our commitment to acting ethically and with integrity in our business relationships. Trinseo UK Limited (Trinseo UK) is a subsidiary of a global materials company, focusing primarily on the manufacture of plastics, latex and synthetic rubber. Our ultimate parent is Trinseo SA, a Luxembourg company. Trinseo UK has no manufacturing facilities in the UK but sells its products there and maintains a small office and a small number of employees. We consider our risk of exposure to modern slavery to be limited. Our products are used as materials by customers to make other products.

Trinseo’s longstanding Code of Business Conduct (the "Code"), and its supporting Labor and Human Rights Policy, emphasize the importance of complying with all human rights and labor laws, including eradicating modern slavery, and promoting respect and dignity for all workers.

In April 2015, Trinseo published a comprehensive Supplier Code of Conduct on its public website, provided awareness training to its employees, issued a press release, and conducted mailings to major raw material suppliers. The Supplier Code’s scope includes provisions specifically prohibiting modern slavery.

In July 2018, Trinseo published its 2018 Sustainability and Corporate Social Responsibility Report, https://p.widencdn.net/8l9qwi/Trinseo-2018-Sustainability-and-CSR-Report, which announced Trinseo’s adoption of the Global Reporting Initiative (GRI) for public sustainability reporting. Trinseo’s report references GRI 102.6 and reiterates Trinseo’s commitments and expectations with respect to modern slavery for its employees and its contractors.

Trinseo’s due diligence processes are set forth below.

Verification: For its major feedstock purchases, Trinseo’s protocol for verification includes the use of a scorecard process globally for selection and retention of suppliers that preferentially scores suppliers with corporate responsibility policies, including those  prohibiting modern slavery.

Auditing: Other than the scorecard process noted above, Trinseo currently does not audit its suppliers’ efforts to evaluate compliance with company standards for modern slavery in its supply chains. However, it has reserved its right to do so in the Trinseo Supplier Code of Conduct and has also set forth its expectation that suppliers will implement controls.

Certification: In addition to its scorecard approach, Trinseo contracts and purchase order terms and conditions require its suppliers to comply with the principles set forth in its Supplier Code of Conduct, which includes the specific prohibition against modern slavery.

Internal Accountability: Noncompliance with company standards can result in action up to and including dismissal of a company employee, contractor or supplier. The Supplier Code of Conduct, as well as Trinseo’s Code of Business Conduct, encourages employees and suppliers to report any violations of the Code to a confidential ethics hotline. Trinseo’s Chief Compliance Officer ensures that reports of violation are investigated and appropriate corrective/preventative actions are put into place. Trinseo maintains a zero-tolerance non-retaliation policy. 

Training: Trinseo has provided Code of Business Conduct training to its employees, and requires annual certification by its employees with respect to the Code and its supporting policies, including its Labor and Human Rights Policy. Trinseo also has provided training on the Supplier Code of Conduct. This topic includes the topic of modern slavery, with specific training provided on these topics to the procurement team.

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