De Nora and Subsidiaries Disclosure Under The California Transparency in Supply Chain Act of 2010
De Nora’s Code of Ethics establishes respect for human rights as a fundamental De Nora principle, and one that both De Nora employees and suppliers are expected to honor. De Nora’s Ethics Guide clearly prescribes that its suppliers not use slavery or human trafficking in connection with any product supplied to De Nora. De Nora suppliers have been advised of and are required to adhere to De Nora’s Supplier Code of Ethics in providing products to De Nora.
While De Nora may periodically audit its suppliers for a variety of reasons; typically those audits are not performed primarily to determine compliance with the prohibition against slave labor or human trafficking. Such audits typically take the form of a quality questionnaire completed by the supplier and site visits by De Nora personnel. De Nora generally does not engage third parties to evaluate or verify compliance with human trafficking or slave labor laws. However, De Nora promptly and thoroughly investigates any claims or indications that a supplier is engaging in human trafficking or slave labor, or is otherwise not complying with De Nora’s Code of Ethics or Supplier Code of Ethics. De Nora does not currently require direct suppliers to expressly certify that the materials incorporated into their product comply with applicable laws regarding slavery and human trafficking. Any claim regarding such laws made through our supply chain would be reported to our Chief Purchasing Officer along with the resolution of the claim and/or the findings of the investigation. De Nora will not continue to purchase goods or services from any supplier that is found to be engaging in human trafficking or using slave labor.
Supply chain management and other De Nora executives receive periodic training on De Nora’s Code of Ethics and Supplier Code of Ethics, which include prohibitions regarding slavery or human trafficking in De Nora’s supply chain and operations. Employees or contractors of De Nora found to be acting in violation of De Nora’s Code of Ethics are subject to sanctions as determined by De Nora.