Human Rights Statement

California Transparency in Supply Chains Act of 2010

 

Disclosure of Bostik, Inc.

Bostik’s Support of Human Rights in Our Business Practices

California Transparency in Supply Chains Act of 2010 

In September 2010, the California legislature passed the California Transparency in Supply Chains Act (the “Act”), which requires retailers and manufacturers operating in the state of California to make public the steps they have undertaken to eradicate slavery and human trafficking from their supply and distribution chains. 

Beginning January 1, 2012, the Act specifically requires retail sellers and manufacturers to disclose the extent of their efforts in relation to the following five points: 

Number 1: Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

Number 2: Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit. 

Number 3: Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. 

Number 4: Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. 

Number 5: Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. 

Bostik relies on a global supply chain, as well as manufacturing partners, and Bostik expects both raw material suppliers and manufacturing partners (collectively, “Suppliers”) to follow principles concerning human trafficking and slavery in accordance with Bostik’s policies and applicable law. 

Bostik has undertaken the following efforts to ensure and verify the absence of slavery and human trafficking in our supply chain: 

Number 1: Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery.  The disclosure shall specify if the verification was not conducted by a third party. 

Bostik supports the Business Conduct and Ethics Code of our parent company, Arkema, Inc.  Our commitment is inspired by principles derived from fundamental treaties including the Universal Declaration of Human Rights of 1948, the principles of the International Labor Organization, the Guidelines for multinational enterprises of the OECD and the principles of the United Nations World Pact. The Business Conduct and Ethics Code can be found in the Ethics and Integrity section on Arkema.com. The Code of Conduct covers issues such as upholding human rights, fighting corruption and fraud, financial transparency, and respect for people.  Bostik requires that employment be freely chosen and not illegally forced, in addition to other similar commitments to ensure that our Suppliers are not engaging in illegal forced or child labor. 

Bostik regularly evaluates and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. Each Supplier is required to commit to using principles equivalent to those in the Code of Conduct. Bostik continually puts in place measures to verify Supplier adherence to principles agreeable to Bostik concerning human trafficking and slavery. 

Number 2: Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit. 

Bostik implements an audit program, coordinated by our Ethics Committee, to ensure that Suppliers are properly following the Code of Conduct. 

Bostik regularly reviews our existing Supplier base and assesses all potential Suppliers to determine the level of risk associated with each Supplier with respect to compliance with the Supplier Code of Conduct.  Audits, which are announced, are conducted internally by Bostik personnel. 

Number 3: Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. 

Bostik is continually putting into place measures that require all manufacturing and purchasing agreements to include a provision to ensure that every factory that manufactures Bostik products or provides the raw materials for Bostik products complies with the Code of Conduct and all relevant national and local laws – including those related to anti-slavery and human trafficking. 

Number 4: Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. 

Bostik is developing an internal process to address potential violations of any human rights.  In the event Bostik determines that a Supplier potentially failed to meet Bostik’s standards regarding human trafficking and slavery, Bostik will provide such Supplier with an opportunity to remedy any such potential noncompliance. Bostik will then subsequently conduct an audit to ensure that the potential for noncompliance has been eliminated. If a Supplier does not correct the noncompliance, Bostik will be prepared to end the relationship with that Supplier. 

Number 5: Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

Bostik trains those employees responsible for supply chain management on how to identify and respond to supply chain issues, such as human trafficking, slavery, and child labor.  Bostik requires all of its employees and contractors to comply with the Code of Conduct, which includes provisions aimed at ensuring that illegal forced labor is not permitted at any Bostik business partner or Supplier operations.

Conclusion 

Bostik’s current practices help prevent human trafficking and slavery within and beyond its supply chain and manufacturing process. Bostik continues to refine and develop procedures to prevent human rights violations in its supply chain and manufacturing process and will update this document accordingly.

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