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UK Modern Slavery Act

The UK Modern Slavery Act of 2015 is focused on eliminating slavery and human trafficking from global supply chains. This act requires companies that do business in the UK to disclose what efforts their organizations engage in to ensure their supply chain is free of human rights violations.

Element Solutions Inc’s Social Responsibility

Element Solutions Inc and its subsidiaries (“Element Solutions”) have implemented a comprehensive corporate social responsibility program intended to help us operate within the highest standards of business ethics and in accordance with all applicable laws and regulations.

As good corporate stewards, Element Solutions will not knowingly work with any suppliers that engage in human trafficking and/or slavery. As part of our comprehensive social responsibility program, we conduct audits which serve as a starting point to understand suppliers’ compliance infrastructure. Issues such as human trafficking, slavery, forced/prison labor and child labor are zero tolerance violations and Element Solutions will not conduct business with suppliers we discover have such practices. Our audits help us to verify that all labor at our suppliers’ factories is voluntary.

In addition, Element Solutions’ Supplier Code of Conduct explicitly requires that our suppliers comply with laws that prohibit harassment, employment discrimination, human trafficking and/or child or forced labor. All suppliers who sign the Supplier Code of Conduct must adhere to our comprehensive social responsibility requirements and are to follow all applicable law and regulations.

Highlighted below are the actions we are taking to address modern slavery in our businesses and supply chains:

Verification:

  • Our verification of social responsibility standards consists of both internal and external audits
  • Random onsite visits at factories
  • Worker Interviews

Supplier Audits:

  • Internal or external audits
  • Certifications and supporting documentation
  • Root-cause analysis to drive issue resolution
  • Corrective action plans developed with suppliers to create sustainable improvements

Certification:

  • Key program documents, such as our Business Conduct and Ethics Policy and Supplier Code of Conduct, outline our strict social responsibility requirements
  • All Suppliers that sign the Business Conduct and Ethics Policy and Supplier Code of Conduct must adhere to our comprehensive social responsibility requirements and are to follow all law and regulations in the jurisdictions in which our products are manufactured

Internal Accountability:

  • Our Business Conduct and Ethics Policy maintains internal accountability standards and procedures regarding employees and officer compliance with applicable laws and our high ethical standards

Training:

  • We provide training to employees on our Business Conduct and Ethics Policy, upon retention or as refreshers
  • To improve our supply chain, we work with our suppliers on an ongoing basis through: supplier training/ development; capacity building; root cause analysis and onsite visits to ensure our suppliers are meeting long- term compliance objectives
  • Various forms of training to include: in person; roundtables; webinars and e-learning

For additional information, please see our Business Conduct and Ethics Policy or Supplier Code of Conduct.

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