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As adopted December 2019

 

Kraton Corporation and each of its wholly-owned subsidiaries are committed to conducting business in an ethical and responsible manner. This Supplier Code of Conduct (“Code”) sets forth basic principles for a supplier’s conduct when working with us.

 

  1. INTEGRITY AND ETHICS

    We expect our suppliers to conduct business ethically, with integrity, and in compliance with the law.

    1. Avoid Conflicts of Interest: Suppliers will avoid any interaction with our employees that may conflict, or appear to conflict, with that employee’s acting in our best interest.
    2. No Bribery: Suppliers will not engage in any form of commercial bribery or otherwise offer incentives or gifts to any of our employees in order to obtain or retain our business.
    3. Fair Competition: Suppliers will avoid agreements or actions that illegally restrain trade, restrict competition, or violate antitrust and competition laws.
    4. Fiscal Integrity: Suppliers will maintain accurate books and records in compliance with all applicable laws, regulations, and contractual obligations.
    5. Protect Information: Suppliers will ensure compliance with laws and directives relating to the protection, transfer, access, and storage of personal information. Suppliers will protect our confidential information to prevent its misuse, theft, improper disclosure, or use to either engage in, or support, insider trading.
    6. Global Trade: Suppliers will comply with all applicable laws and regulations concerning embargoes and sanctions and will not, directly or indirectly, conduct transactions with individuals, entities, or countries subject to restricted party or embargoed country lists.
  2. SUPPLIED MATERIALS.

    We expect our suppliers to be dedicated to responsible sourcing.

    1. Conflict Minerals: Suppliers will abide by our Conflict Minerals Policy and all applicable laws and regulations related to Conflict Minerals. Suppliers will provide us all necessary information to facilitate reasonable country of origin inquiries and due diligence.
  3. HUMAN RIGHTS AND LABOR.
    We expect our suppliers to respect the human rights of their employees and treat them fairly, in accordance with all applicable laws.

    1. Work Environment: Suppliers will promote a work environment that values diversity and is free from unlawful harassment, discrimination, violence, threats of violence, or coercion.
    2. No Child Labor: Suppliers will comply will all applicable child labor laws.

    3. No Forced or Compulsory Labor: Suppliers will not use forced or involuntary labor, including prison labor, indentured labor, bonded labor, or slave labor.

    4. Wages, Benefits and Working Hours: Suppliers will comply with all applicable laws governing wages, working hour requirements, compensation, benefits, and overtime.

  4. ENVIRONMENT, HEALTH, AND SAFETY.
    We are committed to respecting the environment and creating safe and healthy workplaces. We are committed to Responsible Care® and expect our suppliers to make similar commitments to continuously improve their environmental, health, and safety performance.

    1. Environment: Suppliers will comply with all applicable environmental laws and regulations, including those relating to hazardous materials, paper raw materials, wastewater, and solid waste and air emissions.

    2. Sustainability: Suppliers will aim to reduce the environmental impact of their business operations and promote the sustainability of natural resources

    3. Health & Safety: Suppliers will comply with all applicable occupational health and safety laws. We expect our suppliers to create a safe workplace for their employees.

COMPLIANCEWe expect our suppliers to comply with our policies and all other applicable laws in their provision of services or products to us. We reserve the right to assess and monitor a supplier’s compliance with this Code.


REPORTING MISCONDUCT.  Suppliers should provide a confidential and secure mechanism for employees to raise grievances. Suppliers who believe our employees or anyone acting on our behalf has engaged in illegal or otherwise improper conduct with respect to their business with the supplier should report the matter to their Kraton representative or via confidential letter to: Kraton Corporation, 15710 John F. Kennedy Blvd., Suite 300, Houston, TX 77032, Attn: General Counsel and/or Attn: Global Compliance Manager. A supplier’s relationship with us will never be affected by a good faith report of potential misconduct.