The California Transparency in Supply Chains Act of 2010 (the “Act”) entered into effect on January 1, 2012. The law requires manufacturers and retailers to make publicly available information related to their efforts to eradicate the risks of slavery and human trafficking from their supply chains. Although LyondellBasell does not currently:
- verify product supply chains to evaluate and address these risks,
- conduct audits of suppliers to evaluate supplier compliance with company standards regarding these risks,
- require all of our direct suppliers to certify that the materials incorporated in our products comply with laws regarding slavery and human trafficking in the countries where they do business,
- maintain internal standards and processes for employees and contractors who fail to meet company standards regarding these risks,
- provide training for employees who have direct responsibility for supply chain management on this subject matter,
LyondellBasell is committed to conducting business in an ethical and responsible manner, which includes complying with applicable slavery and human trafficking laws. Most of LyondellBasell’s direct suppliers are located in the United States or in Western European countries that have extensive laws prohibiting slavery and human trafficking. LyondellBasell does not typically have direct relationships with suppliers in at-risk countries identified in the U.S. Department of State’s 2018 Trafficking in Persons Report and the U.S. Department of Labor’s 2016 List of Goods Produced by Child Labor or Forced Labor.
Below are the LyondellBasell programs and standards that reflect the objectives of the Act:
- U.S. Customs – Trade Partnership Against Terrorism (C-TPAT)
LyondellBasell has actively participated in the U.S. C-TPAT program since 2003. C-TPAT is a voluntary U.S. government program designed to increase security throughout the global supply chain. The C-TPAT program involves risk-based audits of the company and unannounced audits of suppliers.
- Authorized Economic Operator (AEO) in the European Union.
Since 2010, LyondellBasell has actively participated in the AEO program in the European Union. AEO certifications are based on a voluntary certification program which aims to enhance international supply chain security, facilitate legitimate trade and ensure the integrity of the global supply chain. The AEO certification is granted by national customs authorities according to uniform criteria and requires, inter alia, high level of control of the flows of goods and the absence of serious or repeated infringements of customs legislation and taxation rules, including no record of serious criminal offences relating to the economic activity of the AEO. The AEO program involves customs audits prior to granting AEO certification and continuous supervision by customs authorities (including ad-hoc audits) of the activities of already AEO certified companies.
- LyondellBasell’s Purchase Order Terms and Conditions
LyondellBasell’s purchase order terms and conditions require suppliers to comply with all applicable laws, including forced labor and human trafficking laws.
- LyondellBasell’s Code of Conduct
LyondellBasell’s Code of Conduct embodies our dedication to conducting business ethically and responsibly by obeying the law and enabling a safe and productive work environment. LyondellBasell’s Code states that “we take great care to uphold human rights in all of our operations and facilities, regardless of local custom. We recognize that our Company has a responsibility to respect and protect human rights by doing the following: We do not use child or forced, indentured or involuntary labor.”
All employees, officers, directors, and anyone doing business on behalf of LyondellBasell are expected to know and abide by this Code at all times. Rigorous training on the content and application of the Code is mandatory for each and every employee, and each employee must periodically acknowledge that they have read, understood, and agree to comply with the Code. LyondellBasell takes seriously and fully investigates all potential Code violations. The failure to report any suspected Code violation or misconduct immediately may also be considered a violation of the Code. When an allegation of an employee Code violation is substantiated, the relevant management team reviews the investigation findings and determines disciplinary action consistent with the severity of the violation. Disciplinary action can include verbal or written warning, suspension with or without pay, demotion or, for the most serious offenses or repeated misconduct, employment termination.