Trinseo’s activities related to ethics and compliance are overseen by the chief compliance officer, who also chairs Trinseo’s ethics and compliance committee. The chief compliance officer is responsible for the oversight and management of the Ethics and Compliance program, which is comprised of nine senior Trinseo executives representing diverse functions and geographies.
The Ethics and Compliance Committee reviews, modifies, and updates the Code of Business Conduct and its supporting policies on an ongoing basis. The Committee also oversees the responses to any ethics or compliance reports or questions, conducts or monitors any investigatory activity, and assists in communicating the ethics and compliance program to Trinseo’s employees and the public. Trinseo has a rigorous reporting program for ethics and compliance issues that includes an expectation that employees speak up and report any issues. We have contracted with a third party to provide an ethics and compliance hotline, which allows anonymous reporting of ethics and compliance concerns or allegations where legally possible.
Trinseo’s web-based ethics and compliance training module is available in 10 languages, and more than 96 percent of employees have completed the training as of December 2015.