Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor 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.
Pilot Chemical Corp. and its affiliates (together, the “Company”) have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we will include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to email@example.com.
Compliance with the policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your supervisor or manager as soon as possible if you believe or suspect that a conflict with this policy or a breach of this policy has occurred or may occur in the future. Those not employed by the Company should make use of the Company’s anonymous reporting hotline in such an instance, either by calling 833-290-0001 or visiting www.lighthouse-services.com/pilotchemical.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or supervisor or report it via the anonymous reporting hotline detailed above.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should immediately inform your supervisor or manager or file a report via the anonymous reporting hotline detailed above. If the matter is not remedied, and you are a Company employee, you should raise it formally to the Company’s Human Resources department at firstname.lastname@example.org.
Communication & awareness of this policy
A copy of this policy shall be provided as part of the onboarding process to all new Company employees as well as to third parties providing goods or services to us. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this policy
Any employee who breaches this policy may face disciplinary action, up to and including termination. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.
Last updated: 10/11/2021