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.

Trinseo published a comprehensive Supplier Code of Conduct on its public website, provides awareness training to its employees, 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.

Verification: For procurement of goods and services, Trinseo’s protocol for verification includes the implementation of an automated, purchased know- your- supplier solution to enable our procurement organization globally to assess our suppliers across key risk and compliance parameters, including modern slavery. This program utilizes various partners. The assessments of suppliers is ongoing and if an issue is flagged, the supplier is contacted, and the issue addressed, up to and including termination.

Auditing: In addition to the verification and assessment process noted above
Trinseo has reserved its right to audit in the Trinseo Supplier Code of Conduct and has also set forth its expectation that suppliers will implement controls.

Certification:  In addition to its assessment program, 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 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. Trinseo has launched a specific training program on Human Trafficking to educate relevant Trinseo functions.

Updated Sept 2021

Trinseo UK Limited’s Modern Slavery and Human Trafficking Statement

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

Trinseo is committed to improving our practices to combat slavery and human trafficking in our supply chains or businesses. We have zero tolerance to slavery and human trafficking. 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 S.A. 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 modem slavery to be limited. Our products are used as materials by customers to make other products.

Trinseo's  long standing 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 modem slavery, and promoting respect and dignity for all workers.

Trinseo has published a comprehensive Supplier Code of  Conduct on  its public websites, 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 2021, Trinseo published its Sustainability and Corporate Social Responsibility Report, https://www.trinseo.com/Sustainability Trinseo has adopted the Global Reporting Initiative (GRI) framework for public sustainability reporting, and includes Trinseo's commitments and expectations with respect to modem slavery for Its employees and its contractors.

Trinseo's due diligence processes to identify and mitigate risk of human trafficking are set forth below:

Screening: Trinseo uses a software tool that includes modern slavery screening of its suppliers.  This integrated risk management tool includes an alert in the event the tool finds an issue, from negative press or illegal activity, so that Trinseo can avoid doing business with the supplier.

Compliance: Trinseo’s 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 modem slavery. It has reserved its right to audit for compliance to the Trinseo Supplier Code of Conduct and has also set forth its expectation that suppliers will implement appropriate controls.

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 modem slavery. Trinseo has launched a specific training program on Human Trafficking to educate relevant Trinseo  functions.

This statement is made pursuant to section 54(1) of the Modern Slavery Action of 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2021.

 

Stephen Wilkes

Director

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