TRANSPARENCY IN SUPPLY CHAIN AND MODERN SLAVERY DISCLOSURE STATEMENT
Ashland Global Holdings Inc. (“Ashland”) has issued this statement in accordance with the United Kingdom Modern Slavery Act of 2015* and the California Transparency in Supply Chains Act of 2010 to describe various steps taken to avoid/combat any form of slavery or human trafficking in our supply chain.
Ashland Overview and Supply Chain Structure
Ashland Global Holdings Inc. (NYSE: ASH) is a premier specialty materials company with a conscious and proactive mindset for sustainability. The company serves customers in a wide range of consumer and industrial markets, including adhesives, architectural coatings, automotive, construction, energy, food and beverage, nutraceuticals, personal care and pharmaceutical. Approximately 4,200 passionate, tenacious solvers – from renowned scientists and research chemists to talented engineers and plant operators – thrive on developing practical, innovative and elegant solutions to complex problems for customers in more than 100 countries.
As a global corporation with manufacturing operations around the world, Ashland relies on a vast network of suppliers. These supplier relationships are critical to our success. In keeping with our values, we have taken the steps outlined in the following sections to ensure that the suppliers we select and partner with meet our standards and adhere to our expectations for ethical conduct.
Commitment and Policy
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. We respect the personal dignity of every human being and comply with all applicable human rights laws. 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. Ashland has established an accountability framework relating to trafficking and slavery. This framework consists of our Global Code of Conduct, Transparency in Supply Chains policy, Supplier Code of Conduct, and our Sustainability Report.
Ashland’s Global Code of Conduct states:
We have zero-tolerance policies for the use of child labor, forced labor, human trafficking or land-grabbing practices. We will also refuse to do business with subcontractors, business partners and suppliers who engage in these practices.
Ashland’s Supplier Code of Conduct States:
You (the supplier) shall not engage in or support forced, or compulsory labor as defined by ICO Convention No. 29 including bonded, slavery, and human trafficking practices. All work performed must be voluntary, and employees have the right to terminate employment with reasonable notice.
Ashland’s Child and Forced Labor and Human Trafficking policy states:
Ashland, 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.
Supplier Code Certification
The Supplier Code of Conduct is distributed to all critical suppliers and Ashland requires these suppliers to certify their compliance with the Code. The Supplier Code of Conduct outlines what Ashland expects from its suppliers with respect to human rights, labor and employment rights, environmental health and safety, business ethics and social responsibility, and global trade practices. Suppliers are expected to adhere to this code, and must operate in full compliance with the laws and regulations of the countries they operate. When local laws and regulations are less restrictive than this code, suppliers are expected to adhere to Ashland's principles. Failure to comply with internationally recognized standards, and the standards set forth in this document, may result in the termination of the supplier's contract.
Verification and Risk Assessment
Supplier Code Certification responses received from suppliers are reviewed and verified and required actions are defined. Risk is assessed using many factors and is then used as an input to both the due diligence (new suppliers) and audit evaluation processes.
Due Diligence and Audits
Should risk be deemed elevated for new suppliers, a targeted due diligence process is performed and required actions are defined. If risks are deemed elevated for existing suppliers, we utilize 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,” suppliers deemed high risk may be included in our audit program that includes human trafficking and slavery as well as other topics.
In addition, Ashland is a member of EcoVadis, a third-party platform by which Ashland can measure a suppliers’ social, environmental and ethical performance. All new suppliers are required to join EcoVadis or provide confirmation that they are enrolled in a comparable sustainability program prior to onboarding and current suppliers are being asked to join as well.
Accountability and Measuring Effectiveness
Ashland encourages an open environment where concerns can be raised, and people feel confident to speak up. Multiple channels are provided to employees to speak up including a 24/7 hotline with language support and an on-line form version. In the past year, Ashland did not have any reports or investigations that were indicative of either modern slavery or human trafficking.
Ashland has an online course to help employees better understand responsible supply chain practices and how they impact business including how to identify, prevent and mitigate human trafficking and forced 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.
Ashland is committed to improving our understanding and management of modern slavery risks over time. As we learn from our risk assessments we expect our approach to continue to evolve, our practices to become more refined and our capabilities to mitigate and support slavery and human trafficking risks to become more robust.
Ashland CEO/Chairman of the Board
* With regard to the UK Modern Slavery Act, this disclosure is made for and on behalf of, and approved by the boards of directors of:
Ashland Specialties UK Limited
ISP Holdings (UK) Limited
ISP Microcaps (UK) Limited