California Transparency in Supply Chains Act Disclosure (SB657)

Chevron Phillips Chemical Company LLC and its wholly owned subsidiaries around the world (together “CPChem”) are committed to human rights, anti-human trafficking efforts, and ensuring that their supply chains reflect CPChem’s values and respect for human rights and anti-human trafficking efforts. CPChem is committed to ensuring responsible and ethical business practices and instituting anti-human trafficking measures. Corporate policy provides that CPChem’s relationships with suppliers, service providers and third-party labor providers (collectively, “Suppliers”) shall be based on lawful, efficient and fair practices. CPChem’s Suppliers are expected to ensure materials incorporated into the products manufactured by, and services provided to, CPChem are generated in compliance with all laws.

CPChem demands a commitment to ethics and compliance from its employees, including compliance with laws prohibiting forced, compulsory and child labor, and relies on a robust Code of Conduct to set forth expectations for employees.  Employees who violate the spirit or letter of CPChem’s policies or the Code of Conduct are subject to disciplinary action up to and including termination of their employment. Suspected violations may be reported anonymously and are rigorously investigated.     

As required by the California Transparency in Supply Chains Act of 2010 (SB 657), CPChem also states the following:
 
  • Verification: CPChem conducts internal risk assessments with the leadership team of the procurement organization every two years.  A component of those assessments includes a discussion on the risks of human trafficking and slavery, safety, environmental, and other compliance risks within the supply chain. These assessments are conducted in-house without third-party verifiers. At present, CPChem is not engaging in further verification of product supply chains to evaluate and address risks of human trafficking.
  • Auditing: While CPChem’s general practice is to conduct internal periodic announced audits of its global Suppliers, those audits do not currently evaluate Supplier compliance with anti-human trafficking and anti-slavery standards.   
  • Certification: CPChem utilizes third-party labor providers for some labor needs.  Pursuant to contract provisions instituted after 2017, CPChem requires that all new third-party labor providers represent that all labor supplied, including labor that is supplied by subcontractors and agents, are compliant with and abide by all laws, including those pertaining to human rights, anti-slavery, and anti-human trafficking.  As existing contracts with labor providers come up for renegotiation, we intend to incorporate such provisions in those contracts as well. However, CPChem does not seek a certification from third-party labor providers or other third-party service providers. CPChem’s direct supply contracts typically require suppliers, subcontractors and agents to comply with and abide by all laws but do not specifically require suppliers to certify the materials incorporated in the products supplied comply with laws regarding slavery and human trafficking. 
  • Internal Accountability: CPChem is committed to ensuring responsible and ethical business practices. CPChem will exercise its contractual rights against any Supplier found or suspected 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 to set forth expectations for employees.  Every employee is trained on the Code of Conduct on an annual basis and is required to acknowledge and certify compliance with the Code of Conduct.  Employees who violate the spirit or letter of CPChem’s policies or the Code of Conduct are subject to disciplinary actions up to and including termination of their employment. Employees and Suppliers may anonymously report suspected violations. Violations reported in good faith are rigorously investigated, and the results of those investigations are reported as appropriate. 
  • Training: At this time, personnel with primary responsibility for procurement receive awareness-raising training on the issues and laws related to slavery and human trafficking. However, CPChem is not providing training on mitigating risks of human trafficking and slavery to company employees and management who have direct responsibility for supply chain management.