California supply chains transparency disclosure (sb 657)

The California Transparency in Supply Chains Act of 2010 (SB 657) requires large manufacturers and retailers that sell goods in California to make certain disclosures regarding their efforts to address slavery and human trafficking. The Act is intended to ensure that retail manufacturers and sellers are disclosing their efforts to eradicate slavery and human trafficking from their supply chains.

LANXESS is committed to the basic conventions of the United Nations Universal Declaration of Human Rights and is a member of the U.N. Global Compact Initiative. As a member of the U.N. Global Compact Initiative, LANXESS also expects its suppliers to ensure respect for human rights and compliance with applicable laws and regulations on protecting the environment, health and safety in the workplace and using appropriate labor and hiring practices. These expectations are embodied in the LANXESS Supplier Code of Conduct. LANXESS is also a founding member of the Together for Sustainability (TfS) Initiative with other multinational companies to collectively support the principles of the U.N. Global Compact to improve the working conditions in the global supply chain and to develop and implement a global audit program to assess and improve sustainability practices within the supply chains of the chemical industry.

LANXESS is committed to the goals of SB 657 and compliance with all laws and regulations governing efforts to address slavery and human trafficking. LANXESS monitors its supply chain and expects its suppliers to ensure respect for human rights and compliance with laws governing labor and hiring practices. Such monitoring does not currently include a certification regarding the materials used in manufacture by each supplier. LANXESS conducts audits of its suppliers. The audits may be unannounced. All LANXESS suppliers are subject to unannounced audits by independent third parties. LANXESS will take action upon discovery of violations, including requesting a prompt redress of alleged violations, and corrective actions. LANXESS reserves the right to terminate the supplier relationship in the event of a breach of applicable laws or its Supplier Code of Conduct by its suppliers.

LANXESS maintains the highest ethical standards in its business dealings. LANXESS has a robust Compliance Management System (“CMS”), administered by the global Group Compliance Officer through a network of local Compliance Officers, . The CMS consists of a written Code of Conduct - Code for Integrity and Compliance at LANXESS, compliance-related policies and procedures, and mandatory training (both live and e-training) on a variety of topics. The Code of Conduct - Code for Integrity and Compliance at LANXESS addresses our overarching business guidelines. Supplier expectations are outlined in the Supplier Code of Conduct. We ensure compliance by clearly assigning responsibilities within our structural and process organizations, and by implementing an internal control system.