Supply Chain Responsibility

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will go into effect in the State of California. This legislation seeks to end slavery and human trafficking and requires companies to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

Elementis supports international labor laws that seek to prohibit slavery and human trafficking. As a responsible corporate citizen, we seek to ensure that quality and safety standards are maintained throughout our supply chain by well-treated, fairly compensated workers in accordance with all applicable laws. We have undertaken the following efforts to ensure and verify the absence of slavery and human trafficking in our supply chain:

Risk Assessment and Audits: Review of our suppliers to evaluate the risks of human trafficking and slavery. Annual risk assessments of major suppliers will be conducted as part of our business risk management program. Where necessary a third-party audit will be completed on any high-risk suppliers to ensure full compliance with our Purchasing Code of Practice. Our progress will be reviewed and updated, where necessary, annually.

Acknowledgement of Standards: We will promote the importance throughout our supply chain of social responsibility and environmental awareness. Key suppliers will be asked to certify that the materials supplied to us comply with laws regarding slavery and human trafficking in the countries in which they are doing business. Verification of supplier adherence is done internally in accordance with our Purchasing Code of Practice.

Non-compliance: If we believe that a supplier is not in compliance with our standards with respect to our Purchasing Code of Practice, which includes the elimination of slavery and human trafficking, we will provide such supplier with the opportunity to remedy any potential non-compliance through the implementation of a corrective action plan and we will conduct a subsequent audit. Should the supplier continue to fail to meet our standards, we will seek to eliminate such supplier from our supply chain.

Training: We provide all employees who have direct responsibility for supply chain management with training on the mitigation of human trafficking and slavery risks.