California Transparency Act Disclosure

 

California Transparency Act Disclosure

 

DISCLOSURES REQUIRED PURSUANT TO THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

Lucite International is committed to complying with the law wherever it operates and carries out its business activities to the highest ethical standards. Our ethical standards are reflected in our Code of Conduct, which applies to our employees and contractors.

Lucite International’s operations are based on honesty and integrity and a concern for people and the environment. Lucite International expects those with whom we do business to conduct themselves in the same manner and comply with all applicable laws.

Our employees receive regular compliance training on a wide range of topics and employees have access to a 24/7 compliance line to report any concerns they may have, including the way Lucite International does business and any alleged breach of our Code of Conduct. Every call is logged and appropriate action taken to review and resolve the concern expressed.

In keeping with the California Transparency in Supply Chains Act of 2010, Lucite International makes the following disclosures:

Verification: Lucite International does not have a formal program to verify that its suppliers are not engaging in human trafficking or slavery. In the event Lucite International is made aware that a supplier may be engaging in prohibited conduct, Lucite International will undertake such investigation and take such action as it deems reasonable and proper under the circumstances.

Audit: Lucite International does not currently audit its suppliers to evaluate compliance with the company’s standards for human trafficking and slavery in its supply chains.

Certification: Lucite International does not currently require its suppliers certify that materials provided to Lucite International comply with the laws regarding slavery and human trafficking of the country or countries in which Lucite International does business. Lucite International does generally require that its suppliers comply with applicable laws when contracting on Lucite International’s terms and conditions.

Accountability: Lucite International does not maintain formal internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. However, in the event that Lucite is made aware that an employee or supplier engages in or fails to address prohibited conduct, such non-compliance will be addressed as deemed reasonable and proper under the circumstances.

Training: Lucite International does not currently provide 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.