Kraton is committed to 100 percent compliance, 100 percent of the time. Compliance work is overseen by the Audit Committee of the Board and the internal Corporate Compliance Committee (CCC), which reports to the Audit Committee. CCC members consist of Kraton executive leadership and business leaders from Europe, Asia and South America to gain the broadest possible perspective on compliance challenges and how to address them. Our global Ethics and Compliance program is designed to promote and reinforce ethical behavior in every aspect of our business by:

• communicating company expectations for behavior as described in the Code of Ethics and Business Conduct and our other policies covering anti-corruption, anti-bribery, competition law, international trade and sanctions compliance. These policies are posted on the intranet and translated into the primary languages spoken by employees;
• monitoring and auditing compliance with these policies. Every year, Internal Audit undertakes one or more projects directly linked to our biggest compliance risks;
• providing ongoing training in areas of the law that impact our business; and
• investigating allegations of improper conduct that come through the internal whistleblower system or other means.

We provide comprehensive employee training on compliance and key risk areas, such as anti-corruption, anti-bribery and international trade. Non-operator employees must complete two quarterly online compliance trainings. These employees typically have responsibilities where they are likely to interact with customers, suppliers, media or other external parties. Those who do not complete their training on time may be disqualified from receiving part of their year-end bonus.

Employees with more externally-focused roles – such as those in sales and procurement – have frequent, in-person training by senior management with greater emphasis in more challenging jurisdictions and matters.

We also conduct periodic compliance training with distributors, marketing representatives and other third-party representatives. Typically, these sessions are presented in English as well as the attendees’ native languages, ensuring minimal information is lost-in-translation regarding our compliance expectations.

Our Code of Ethics and Business Conduct is available at kraton.com/docs/Code of Ethics.pdf