California Transparency in Supply Chains Act

INFORMATION provided pursuant to the CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Verification: Each Roquette production facility is overseen by the parent Group, and compliance with local laws is a cornerstone principle of the Group. The California Transparency in Supply Chains Act, Cal. Civ. Code § 1714.43, subd. (a)(1), requires this website disclosure relating to efforts to eradicate slavery and human trafficking from supply chains. The Roquette Supplier Code of Conduct requires all suppliers with whom Roquette does business to protect human rights, to subscribe to the work standards articulated by the International Labor Organization (“ILO”), and also to respect and comply with all applicable laws and regulations. Before contracting with any supplier, Roquette requires that the supplier acknowledge and comply with the Supplier Code of Conduct which states that the Supplier Code of Conduct forms part of their contractual obligations. Failure to respect the Supplier Code of Conduct is expressly stated to constitute sufficient reason to terminate business relations without any right to compensation. Roquette does not engage a third-party verifier of its suppliers specifically for human trafficking and slavery.

Audits: Periodic audits of Roquette America manufacturing operations are provided through the Roquette Group. At most Roquette America facilities, third party SEDEX audits have been performed that verify compliance. In the Supplier Code of Conduct, Roquette reserves the authority directly or through an accredited body to carry out any inspections or audits of suppliers required to ensure compliance with the Supplier Code of Conduct.

Certification: Roquette in its Supplier Code of Conduct makes it a condition of entering into supply contracts that suppliers acknowledge and comply with the Supplier Code of Conduct which must be communicated to all supplier employees involved in activities with Roquette America. Suppliers must take all necessary measures to ensure that their own suppliers, subsidiaries, sister companies and subcontractors respect ILO requirements, including to eliminate child labor and forced labor. A formal certification by the supplier limited to human trafficking and slavery is not required.
Internal Accountability: All Roquette employees are given a copy of, and subscribe to, the Roquette Ethics & Responsibilities Charter which adopts the principles established by the ILO, the Universal Declaration of Human Rights, and the UN Global Compact, expressly including elimination of all forms of forced and compulsory labor and child labor. It is also made available on the Group intranet and internet sites and states that the Roquette Ethical Committee is available for employee guidance in particular situations. Emphasis is placed on compliance with all national and international regulations “and to go even further when possible and worthwhile.”

Training: Consistent with the fundamental value of promoting observance of all applicable laws in the locations where it operates, pursuant to the Ethics & Responsibilities Charter, employees and management of Roquette America receive occasional training under the guidance of the Roquette Ethical Committee on the management, inter alia, of compliance with the Supplier Code of Conduct, and thus systems for protecting the fundamental human right to be free from human trafficking and slavery, as well as from child labor.
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