California Supply Chain Act

DISCLOSURES REQUIRED PURSUANT TO THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

Kemin is committed to ensuring that our supply chain reflects Kemin’s values and respect for human rights and the environment. To that end, it is Kemin’s policy that its relationships with its suppliers are based on lawful, efficient and fair practices.  Kemin expects its suppliers to obey the laws that require them to treat workers fairly, provide a safe and healthy work environment and protect environmental quality.  Kemin expects its suppliers to follow its guidelines to help ensure that Kemin’s supplier relationships will not damage Kemin’s reputation.

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.
Kemin uses its own staff to verify supplier compliance with their representations regarding obeying all relevant law. Kemin staff visit suppliers from time to time and Kemin relies on supplier questionnaires to support compliance. We do not use third-party verifiers.

2. Conducts 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.
Kemin ensures compliance with this requirement by conducting onsite audits, desk audits, asking suppliers to fill out questionnaires and obtaining continuing guarantees of compliance with all relevant law.  In addition, Kemin’s purchasing and quality control staff is alert to recognizing environmental, health, safety and labor issues that could cause inconsistent adherence to Kemin’s supplier requirement.  Kemin asks its staff to be vigilant and report all suspicions of improper conduct for any supplier so that an appropriate investigation can be made.

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.
Kemin uses a rigorous auditing process in combination with its purchasing documents to require its suppliers to comply with all relevant law including a requirement that Kemin suppliers do not utilize forced, prison, or indentured labor, or subject workers to any form of compulsion or coercion.  Kemin’s suppliers are to expect the same standards of compliance for their suppliers as well. Kemin includes a clause in our purchase order terms and conditions and supply agreements which stipulates that our suppliers must abide by our anti-slavery and human trafficking standards. Thus, as a condition of doing business with us, and as a means of self-certification, the clause reads: “California Transparency Act.  Seller represents that it complies with all laws regarding slavery and human trafficking in all countries in which it does business, in compliance with the California Transparency in Supply Chains Act of 2010”

4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Kemin maintains internal accountability standards and procedures, which are detailed in our Code of Conduct. Suppliers that fail to comply with the California Transparency in Supply Chains Act of 2010 or meet Kemin’s expectations are terminated.  Employees at all levels who violate the spirit or letter of Kemin’s policies are subject to disciplinary action up to and including termination of employment in accordance with local relevant law and contractual arrangements.

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.
Kemin is developing an online course, which will be offered through our online learning portal, to help employees better understand responsible supply chain practices and what Kemin is doing to identify, prevent and mitigate human trafficking, forced labor and child labor risks within our supply chain. All supply chain management staff will be required to complete this course. This disclosure statement will be updated as soon as the training course is implemented.