California Transparency in Supply Chain Act of 2010

Policies

Evonik is opposed to any use of forced labor or compulsory labor and does not permit the use of child labor in our own operations and our supply chains.

Our most relevant standards of conduct in this regard are the Evonik Code of Conduct, the Policy Statement on Human Rights and the Code of Conduct for Suppliers. Our policies are based on internationally recognized standards and principles such as:

• International Bill of Human Rights
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• ILO Declaration on Fundamental Principles and Rights and Work (ILO Core Labor Standards)

We comply with all locally applicable laws and regulations, including those intending to eradicate slavery and human trafficking. In countries where local laws differ from internationally accepted human rights, we look for ways to implement the above international standards without coming into conflict with local legislation.

Certification

As a basis for successful cooperation, we also expect our suppliers and other business partners to comply with the law and our standards, and to implement appropriate processes to respect human rights. The Evonik Code of Conduct for Suppliers specifies our expectations in this regard. It is communicated to all suppliers in our general terms and conditions of purchase, as well as via contractual compliance clauses.

Verification

The annual Group-wide human rights risk assessment, including risks of human trafficking and slavery, covers Evonik’s own business operations as well as our management of direct and indirect suppliers. In addition, new suppliers are subject to a self-developed supplier validation process based on the values defined in our Code of Conduct for Suppliers. Successfully completed Together for Sustainability (TfS) assessments can similarly be used as evidence of validation. To address identified risks – including of human trafficking and slavery – we implement and continue to develop preventive measures, training and awareness-raising activities.

Audits

During the supplier relationship, we conduct third-party audits on selected suppliers to identify nonconformances, including with regard to human trafficking and slavery. Wherever audits identify shortcomings, we expect our suppliers to implement corrective action plans within a defined timeframe. If the shortcomings are particularly serious and no improvement can be ascertained, we reserve the right to terminate our collaboration with the supplier.

Internal accountability

We require all employees in our global operations to comply with the principles of the Code of Conduct and the Policy Statement on Human Rights, and to actively engage against any violations. We take systematic action to deal with any breaches.

We provide employees and third parties with the means to report, including an electronic whistle-blower system and a toll-free hotline in North America, any noncompliance within our company or related to our business partners. 

Training

All employees receive periodic training on the Group Code of Conduct. We also maintain both an online and face-to-face training on human rights. Employees who themselves may breach human rights or may identify or prevent a breach of human rights are subject to mandatory training. This specifically includes buyers in our procurement organization.