As adopted December 7, 2016
Statement of Policy. A commitment to compliance and to the core value of Integrity is fundamental to the philosophy of Kraton Corporation (“Kraton”). Because of this commitment, it is Kraton’s policy to responsibly source minerals and to work with its global supply chain partners to ensure compliance with appropriate diligence and disclosure requirements relating to Conflict Minerals (defined below). Further, it is our policy to support the observance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High Risk Areas, and to adhere to internal supply chain due diligence measures and internal controls with respect to Conflict Minerals. If our products contain Conflict Minerals that are necessary to the functionality of such products, then our policy is to conduct a reasonable country of origin inquiry to determine whether such Conflict Minerals come from the Democratic Republic of the Congo, or one of the surrounding countries, or from recycled or
DEFINITION OF CONFLICT MINERALS
Conflict Minerals include gold, cassiterite, columbite/tantalite and wolframite and their derivatives, which are limited to tin, tungsten and
EXPECTATIONS OF SUPPLIERS
Kraton does not purchase directly from smelters or mines. However, the international supply chain for these minerals is complex, and the tracing of their origin is challenging. Consequently, Kraton relies on its suppliers to identify the sources of Conflict Minerals and to declare whether the products they sell to Kraton contain Conflict Minerals. Kraton expects each of its suppliers to:
- Identify any Conflict Minerals supplied to Kraton or contained in products supplied Kraton;
- Conduct a reasonable inquiry into the country of origin of Conflict Minerals incorporated into products it provides Kraton, if any;
- Conduct appropriate due diligence on their supply chains in accordance with industry standards;
- Institute risk assessment and mitigation actions necessary to implement such country of origin inquiry and due diligence procedures; and
- Provide additional information reasonably requested by Kraton that is necessary for Kraton to fulfill its own due diligence and disclosure obligations.
Kraton undertakes to regularly perform due diligence and to survey its suppliers to verify compliance with this Policy. Kraton may reconsider its willingness to partner with suppliers that fail to comply with this Policy. General. A copy of this Policy may be obtained on Kraton’s website at www.kraton.com. This information is being provided as of the date set forth above.