Disclosure under the California Transparency in Supply Chains Act of 2010 (SB 657)

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 law was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make more informed choices regarding the products they buy and the companies they choose to support.
 
Chevron Phillips Chemical Company LLC and its affiliated companies around the world (together “CPChem”) are committed to ensuring that our supply chain reflects CPChem’s values and respect for human rights.
 
1. CPChem assesses the risk of human trafficking and slavery in our product supply chain.
To ensure that our supply chain reflects CPChem’s values and respect for human rights, our corporate policy provides that CPChem’s relationships with suppliers shall be based on lawful, efficient, and fair practices. CPChem relies on suppliers who comply with all laws, including those that require them to treat workers fairly, provide a safe and healthy work environment, and protect environmental quality. CPChem verifies its product supply chains to evaluate and address risks of human trafficking and slavery by periodic audits performed by CPChem. Third-party auditors may be contracted by CPChem to conduct on-site inspections; however, the majority of assessments are performed by CPChem personnel. 
 
2. CPChem audits for compliance with our values and respect for human rights. 
CPChem’s general practice is to conduct periodic announced audits of its global suppliers. Over the next several years, CPChem will conduct assessments of many of its suppliers to evaluate compliance with anti-slavery and anti-human trafficking laws. Third-party auditors may be contracted by CPChem to conduct on-site audits of suppliers; however, the majority of assessments are performed by CPChem personnel. CPChem personnel performing these audits are trained to recognize and report non-compliance. 
 
3. CPChem requires its suppliers to certify compliance with all laws, including those pertaining to human rights, anti-slavery and anti-human trafficking.
CPChem suppliers are expected to certify that the materials incorporated into the products manufactured by CPChem comply with all laws, including those pertaining to human rights, anti-slavery and anti-human trafficking.
 
4. CPChem maintains and rigorously enforces internal accountability procedures for employees, contractors, and suppliers regarding compliance with our values and respect for human rights.
CPChem is committed to ensuring responsible and ethical business practices. CPChem will exercise its contractual rights against any supplier found to be in violation of applicable laws.  CPChem also demands commitment to ethics and compliance from its employees and relies on a robust Code of Conduct (“the Code”) to set forth expectations for employees. Each and every employee is trained on the Code on an annual basis and is required to acknowledge and certify compliance with the Code. Employees and contractors who violate the spirit or letter of CPChem’s policies or our Code of Conduct are subject to disciplinary action up to and including termination of their employment. 
 
5. CPChem conducts training on our policies and Code of Conduct, with a particular focus on mitigating risks. 
CPChem sourcing personnel, employees and management with direct responsibility for supply chain management are trained to recognize health, safety, and labor and employment best practices, and are trained to report and investigate all deviations from a best practice. This includes suspicions of forced labor or human trafficking.