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ColorMatrix Europe Limited - Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of ColorMatrix Europe Limited (“ColorMatrix”) for the current financial year.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking.

Organisational structure

ColorMatrix Europe Limited are global innovators in advanced colorant, additive and dosing technologies that are engineered to improve the performance, processing, aesthetics and sustainability of plastic products. Its site in Knowsley UK employs ~140 associates in manufacturing, technology, regulatory, marketing and admin with approximately 60% of our sales supplying affiliates in Europe, India and China for onward sale to customers locally.

ColorMatrix Europe Limited is a wholly owned indirect subsidiary of PolyOne Corporation, a U.S. publicly-traded corporation listed on the New York Stock Exchange with global headquarters in Avon Lake, Ohio, United States. ColorMatrix is part of the Color, Additives and Inks segment.

PolyOne and its global direct and indirect subsidiaries and affiliates, including ColorMatrix (“PolyOne”), are intermediate suppliers of specialty polymers and related raw materials designed to meet the specifications of its manufacturing customers. PolyOne does not manufacture or sell totally finished articles to be sold as consumer goods. In sourcing its own raw materials and in distributing products manufactured by others, PolyOne is required to meet the specifications prescribed by its customers.

More information about PolyOne and its locations can be found on our website – www.polyone.com

Our supply chain

ColorMatrix has a wide ranging supply chain that supports our European operations. Our supply base currently includes 79 suppliers: 61% located within the EU and the remaining 39% split between China, USA and India.

Organizations are being challenged to operate in a more transparent fashion and are expected to disclose more information than ever before; with that in mind, ColorMatrix intends to drive greater disclosure from our suppliers in order to better understand our supply chain and to mitigate any risks related to modern slavery.

In the PolyOne Supplier Code of Conduct, which is applicable to the suppliers of ColorMatrix, PolyOne prescribes that its suppliers should not use slavery or human trafficking in connection with any product supplied to PolyOne. PolyOne currently does not engage in verification of its supply chains to evaluate and address risks of human trafficking and slavery, nor does it currently conduct audits of its suppliers’ compliance with company standards for trafficking and slavery in supply chains. PolyOne currently does not require direct suppliers to certify that the materials incorporated into their product comply with the laws regarding slavery and human trafficking.

Our policies on slavery and human trafficking

The PolyOne Code of Conduct establishes a clear set of ethical and behavioral standards for the employees of PolyOne for our business conduct. We strive to uphold a consistent global standard of ethical conduct, while respecting the cultures and business practices of the countries and local communities with which we interact.

PolyOne includes in its Code of Conduct internal accountability standards related to slavery and human trafficking to which all employees, agents and consultants are required to adhere. In its training programs for employees and managers with direct responsibility for supply chain management, PolyOne is planning to include the need to mitigate the risks of slavery and human trafficking within supply chains.

A full copy of the Code of Conduct can be found here: www.polyone.com/company/policies-and-governance

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk, through 2019 we are aiming to have in place internal systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.

Supplier adherence to our values

As a global company, we work with a wide range of suppliers. We are committed to doing business the right way, including without limitation, conducting business ethically and minimizing the risk of slavery and human trafficking in our own business and in that of our suppliers as much as possible.

During the current year we have completed the process of mapping our suppliers including them in our existing list for supplier risk mitigation, in order to identify the risk of modern slavery.

In the year ahead we intend to carry out a risk assessment of our current key suppliers. The actions below are currently in process:

  1. Develop a supplier/subcontractor engagement letter containing the Modern Slavery Act 2015 clauses which will seek assurance that our suppliers currently have a program to guarantee that human trafficking and slavery do not exist in their operations and supply chain.
  2. Develop of a Human Rights and Anti-Slavery self-assessment questionnaire to clarify and improve our expectations of our suppliers regarding their compliance with the Modern Slavery Act 2015 and any other applicable anti-slavery laws.         
  3. Create a Supplier Due Diligence Audit Questionnaire to consistently support our risk assessment exercises adopting a risk-based approach to ensure compliance with the Modern Slavery Act 2015 when auditing and monitoring our supplier chain. 
  4. Develop a training course on the improved supplier questionnaire and procedures and supplier due diligence process including such aspects as how to identify the risk of modern slavery and how to tackle it through the supply chain transparency requirements. This training will also support the effective implementation of our enhanced Supplier Due Diligence Questionnaire by equipping our employees who are involved in procurement and supplier surveillance with the skills and knowledge to undertake a risk based assessment of modern slavery risks.

Our global quality manager is currently leading the project team in the above tasks.

Training

PolyOne includes in its Code of Conduct internal accountability standards related to slavery and human trafficking to which all employees, agents and consultants are required to adhere. For 2018, 100% of our salaried associates completed the Code of Conduct training.  In 2019 hourly associates will complete in-person code of conduct training, while salaried associates will complete an online version of the training.

PolyOne strives to uphold a consistent global standard of ethical conduct, while respecting the cultures and business practices of the countries and local communities with which we interact. If we fail to live up to these expectations, we want our associates, vendors and stakeholders to let us know. The PolyOne ethics hotline is available globally to make a web-based or telephonic report, with multi-language capabilities, 24 hours a day, seven days a week. The hotline is operated by an external professional service company and ensures anonymity. All calls to the hotline are reviewed by the Corporate Ethics Officer.

Our effectiveness in combating slavery and human trafficking

The following key performance indicators (KPIs) will be used to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains

  • 100% completion of the Code of Conduct for all salaried associates
  • Roll out of a supplier/subcontractor engagement letter to 60% of key suppliers

Our on-going commitment

As part of our modern slavery strategy we will continue to monitor the progress we have made and build on our achievements and initiatives in the next financial year. Our procurement and compliance teams will continue to focus on identifying and addressing any potential risks in our supply chain and the business will continue to provide awareness and training to all of its employees.

We are committed to doing business the right way, including without limitation, conducting business ethically and to minimizing the risk of slavery and human trafficking in our own business and in that of our suppliers as much as possible

This statement is approved by ColorMatrix by its board of directors. View signed document here.

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