COMPANY / CORPORATE COMPLIANCE

Compliance is an operating control, not a statement.

Chemicals move across borders under sanctions law, transport regulation, product registration and customer audit. Our compliance system is built to clear all four before an order is accepted, and to prove it afterwards.

6
COMPLIANCE CONTROLS
100%
COUNTERPARTIES SCREENED
10 days
AUDIT RESPONSE TARGET
0
SUBSTANTIATED BRIBERY CASES
JUMP TO
Report a concern
BUSINESS CONDUCT

What every employee signs.

The business conduct code applies to employees, agents, contractors and anyone acting on Chemtive’s behalf. Breach is a disciplinary matter up to and including dismissal and contract termination.

1.1
Fair dealing

No misrepresentation of specification, origin, availability or lead time in any quotation or negotiation.

1.2
Conflicts of interest

Personal, family or financial interests in a customer, supplier or competitor are declared in writing on arising.

1.3
Gifts and hospitality

Modest and infrequent only, never around a tender decision, and recorded above the disclosure threshold.

1.4
Competition law

No discussion of pricing, allocation or customers with competitors, including in trade association settings.

1.5
Confidential information

Customer formulations and supplier terms are handled on a need-to-know basis and never used commercially elsewhere.

1.6
Accurate records

Batch records, certificates and transport documents reflect what actually happened, without adjustment.

TRAINING
100%

of employees completed conduct and anti-bribery training in 2025, refreshed annually and on role change.

GOVERNANCE

A compliance committee of the CEO, Head of Quality and Regulatory and external counsel meets quarterly and reviews every reported case to closure.

ANTI-CORRUPTION

No facilitation payments. No exceptions.

Chemtive prohibits bribery in any form, direct or through a third party, in every market we operate in. The rule holds even where a payment is customary or a shipment is delayed as a result.

A1
No facilitation payments

Small payments to expedite routine clearance are prohibited even where they are locally common and legal ambiguity exists.

A2
Third parties are our risk

Agents, brokers and customs handlers are contractually bound by the same standard and subject to due diligence.

A3
Approval before payment

Any payment outside standard commercial terms requires prior written approval from the compliance committee.

A4
Report and protect

Employees who refuse a demand and report it are protected, whatever the commercial consequence of the refusal.

Gifts and hospitality above USD 100 require written approval and are recorded in a register available to audit.
Download the policy
TRADE CONTROLS

Screened before the first quotation.

Sanctions lists, dual-use classification and end-use declarations are checked at onboarding, at order entry and again at renewal. Screening is automated against consolidated lists and reviewed manually on any hit.

1
Counterparty screening

Legal entity, beneficial owners and directors screened against consolidated sanctions and watch lists at onboarding.

2
Product classification

Each product assessed for dual-use, precursor and restricted status in both origin and destination jurisdictions.

3
End-use declaration

Restricted materials require a signed statement of intended use and site of consumption before release.

4
Order-entry check

Automated re-screening at order entry catches list changes since the last transaction.

5
Record retention

Screening evidence, declarations and shipping documents retained for the period the destination market requires.

REGIMES WE SCREEN AGAINST
UN
EU
OFAC / US
UK OFSI
Dual-use (EU 2021/821)
REACH
GHS / CLP
IMDG & ADR

Restricted and dual-use substances are flagged in the product finder before a quotation can be raised.

PRODUCT STEWARDSHIP & HSE

Hazardous goods handled by people qualified to handle them.

Classification, labelling, packaging and transport documentation follow the destination market. Storage and loading sites are audited against our HSE standard, not only local minimums.

H1
Classification

GHS classification and destination-market labelling prepared before dispatch, not at the border.

H2
Packaging

UN-approved packaging selected for the mode of transport and the class of goods carried.

H3
Transport

IMDG, ADR and IATA documentation issued by trained dangerous goods safety advisers.

H4
Site standards

Storage, bunding, segregation and loading audited against our standard at every partner site.

CERTIFIED TO
ISO 9001
ISO 14001
ISO 45001
ISO 50001
ISO 22000
ISCC
GMP+
Responsible Care
DATA PRIVACY

What we hold, and what you can ask for.

Chemtive processes customer, supplier and applicant data under a published privacy statement. Requests are answered within thirty days.

What we collect

Contact details, order history, credit information and, for applicants, recruitment records.

How we use it

To quote, supply, invoice and meet legal retention duties. We do not sell personal data.

How it is secured

Access control, encryption in transit and at rest, and vendor assessment for hosted systems.

Your rights

Access, correction, deletion and objection requests answered within thirty days of verification.

SPEAK UP

Report a concern, confidentially.

Employees, customers, suppliers and members of the public can raise a suspected breach of law, our code or our supplier standard. Reports may be made anonymously and retaliation is itself a disciplinary offence.

S1
Line manager

The fastest route for most concerns, and the one we expect employees to try first where it is safe to do so.

S2
Compliance officer

Direct, named contact for matters involving a manager or a commercial relationship.

S3
External hotline

Operated independently, available in local languages, anonymous reporting supported.

S4
Written submission

Post or email to the compliance committee, including from customers and suppliers.

WHAT HAPPENS NEXT
24H
Receipt acknowledged and a case reference issued.
5 DAYS
Initial assessment and assignment of an independent investigator.
30 DAYS
Investigation concluded or an interim update given to the reporter.
CLOSE
Outcome, corrective action and any policy change recorded in the register.
SUPPLIER STANDARD

The same rules, one tier back.

Principals and service providers sign the supplier code covering labour, safety, environment, anti-bribery and sanctions. High-risk suppliers are audited on site.

REQUIREMENT
APPLIES TO
FREQUENCY
EVIDENCE
Signed supplier code of conduct
All suppliers
At onboarding
Countersigned copy
Sanctions and ownership screening
All suppliers
Continuous
Screening record
Quality system certification
Producers
Annual
Valid certificate
On-site HSE audit
High-risk sites
Every 2 years
Audit report and CAPA
Labour and modern slavery declaration
All suppliers
Annual
Signed statement
QUESTIONS

Send your audit questionnaire. We answer it.

Customer audits, supplier qualification packs and regulatory questionnaires are handled by the quality and regulatory team, usually within ten working days.