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.