TRANSPARENCY IN SUPPLY CHAIN DISCLOSURE

Ashland is firmly committed to conducting business throughout the world in accordance with the highest legal and ethical rules and principles. These standards are outlined in our Global Code of Conduct booklet which is provided to every Ashland employee. Consistent with the requirements of our standards and principals, we respect the personal dignity of every human being and comply with all applicable human rights laws. Failure to comply with these standards and principals subjects violators to disciplinary action up to and including termination.

With respect to our supply chain partners, we expect the same commitment to high ethical standards and compliance with applicable laws, including those relating to human trafficking and slavery.

The following summary describes Ashland’s efforts as per the numbered sections from the Act:

  1. 1. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

    Responses from the Supplier Code of Conduct certification process are reviewed by the Procurement Department in consultation with the Law Department (as needed) and required actions are defined. Risk is assessed as an input to the audit evaluation process.

  2. 2. Conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

    Should risk be deemed elevated, the Procurement team utilizes a "paper self-audit" approach to obtain additional information from our suppliers on human trafficking and slavery in their supply chains. Based on the result of the "paper self-audit," the Procurement team has the option to include suppliers deemed high risk in our audit program. The supplier audit program covers various topics including Environmental, Health, Safety and Quality as well as key Procurement topics including human trafficking and slavery. These audits are conducted by both internal Ashland auditors and external suppliers, and they are always announced in advance.

  3. 3. Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

    Ashland has established a Supplier Code of Conduct, that is distributed to all critical suppliers. all critical suppliers are required to provide a response and certify their compliance to this code.

  4. 4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

    Ashland has established an accountability framework relating to trafficking and slavery. This framework consists of our Global Standards of Business Conduct, Transparency in Supply Chains policy and our Sustainability Report.

    Ashland’s Global Standards of Business Conduct states:

    We believe in treating people with dignity and respect, including people outside the company. As employees, we are expected to hold ourselves accountable to high professional standards at all times, with mutual respect being the basis of all professional relationships.

    Ashland’s Child and Forced Labor and Human Trafficking policy states:

    Ashland Inc., its commercial units and majority-owned or controlled subsidiaries (“Ashland”) is committed to respecting the human rights of others.  Ashland will not tolerate the use of child or forced labor, slavery or human trafficking in any of its facilities or operations. Ashland will not tolerate the physical punishment, abuse, involuntary servitude or exploitation of any worker. Ashland expects our suppliers and contractors with whom we do business to uphold the same standards. Ashland shall discontinue the business relationship with any individual or company that does not follow the same standards.

    Ashland’s Sustainability Report states:

    Child labor (HR6): Ashland abides by child labor laws and does not employ underage workers in its worldwide operations.

    Forced and compulsory labor (HR7):  None of Ashland’s operations employs forced or compulsory labor.

  5. 5. Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

    Ashland has developed an online course to help employees better understand responsible supply chain practices and how they impact business, and what Ashland is doing to identify, prevent and mitigate human trafficking, forced labor and child labor risks within our supply chain. On a periodic basis, Supply Chain employees are required to complete this course. This training is also available to all Ashland employees through our Learning Management System course catalog.  

    In addition, all Ashland employees worldwide are required to complete annual training on the legal and ethical standards presented in the Global Code of Conduct.

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