Disclosure for Compliance with the California Transparency in Supply Chains Act of 2010 (“CTSCA”)

Arkema Inc. (“Arkema”) has adopted a policy to comply with the California Transparency in Supply Chains Act of 2010 (“CTSCA”), and is developing a framework to disclose the work we are doing to assess the risk of human trafficking and slave labor in our direct supply chain.  The following disclosures are intended to address the requirements of the CTSCA. 

• With respect to verifying product supply chains to evaluate and address risks of human trafficking and slavery, Arkema has decided to evaluate all of the vendors (other than energy and utility vendors) with whom we do business, regardless of their individual potential risk of violation. The program will not include the energy and utility vendors, which are highly regulated and are limited in availability in certain geographic areas, and with some of whom we do not have direct contracts.  
• With respect to auditing suppliers to evaluate compliance with our company standards for trafficking and slavery in supply chains, and disclosing the use independent third party auditors, Arkema has no plans to send audit teams (either third party or internal) to visit and review our suppliers.  Instead, Arkema will rely on self-testing and certification.
• Arkema is in the process of initiating a program to require direct suppliers to certify compliance with the laws regarding slavery and human trafficking of the country or countries in which the suppliers are doing business.  The certification program will require that, among other things, all new direct suppliers, and many of our largest, existing direct suppliers currently under contract, sign a new Vendor Certification Form stating their compliance with the laws regarding slavery and human trafficking of the country or countries in which the suppliers are doing business.  A similar requirement will be incorporated into new contracts and Purchase Orders as they come up for renegotiation and or renewal. 
• With respect to maintaining internal accountability standards and procedures for employees and/or contractors failing to meet company standards regarding slavery and trafficking, Arkema will revise its Supplier Assessment / Vendor Acquisition section of our Purchasing Cycle Control Template for the 2012 testing period to reflect the new policy. 
• With respect to providing its employees, who have direct responsibility for supply chain management, training on human trafficking and slavery, Arkema is in the early development stages of such a program.