PEOPLE / CODE OF ETHICS

One code. Every employee, every supplier, every market.

Chemtive handles hazardous materials, restricted goods and other people’s money. The code is short on purpose: eight commitments, one decision test, and a route to raise anything that does not look right.

8
COMMITMENTS
100%
EMPLOYEES RE-SIGN ANNUALLY
0
SUBSTANTIATED BRIBERY CASES
30 days
INVESTIGATION TARGET
THE CODE

Eight commitments

Signed by every employee on joining and re-signed each January. The full policy is listed with the documents below.

01 Tell the truth about the product

No misrepresentation of specification, origin, purity, availability or lead time, whether in a quotation, a certificate or a conversation.

HONESTY
02 No bribery, in any form

No bribes and no facilitation payments, even where they are locally common. Refusing one is always the right call, whatever the order is worth.

ANTI-CORRUPTION
03 Respect trade controls

Sanctions, dual-use and end-use screening at onboarding, order entry and renewal. If the end use is unclear, the shipment waits.

TRADE COMPLIANCE
04 Safety over schedule

Anyone can stop a batch, a loading or a shipment on a safety concern, and no one is ever asked to justify caution afterwards.

ISO 45001
05 Protect what is not ours

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

CONFIDENTIALITY
06 Treat people as equals

No harassment, no discrimination, no retaliation. Hiring, pay and promotion decisions are made on evidence against a written profile.

RESPECT
07 Keep accurate records

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

INTEGRITY
08 Declare the conflict

Personal, family or financial interests in a customer, supplier or competitor are declared in writing as they arise, not when asked.

TRANSPARENCY
WHO IT COVERS

Everyone in the chain

Every Chemtive employee, contractor and agency worker, in all eighteen countries.
Every director and officer, with no exemptions for seniority.
Every supplier, producer, agent, broker and customs handler, through the supplier code of conduct.
Joint ventures and toll manufacturing partners, written into the manufacturing agreement.
THE DECISION TEST
Four questions, before you act
01
Is it legal in every jurisdiction the transaction touches?
02
Is it safe for the people handling the material and everyone downstream?
03
Is it recorded accurately, and would it survive an audit?
04
Would I say it out loud to the customer, the regulator and my team?

If the answer to any of the four is no, or you are not sure, stop and ask. Asking is never a career risk here; proceeding quietly is.

SPEAK UP

Four routes, all protected

Retaliation against anyone who raises a concern in good faith is itself a dismissible breach of this code.

Line manager

The fastest route for most concerns, and where we expect you to start when it is safe to do so.

IMMEDIATE
Compliance officer

A named, direct contact for anything involving a manager or a commercial relationship.

NAMED CONTACT
External hotline

Independently operated, available in local languages, anonymous reporting supported.

24/7
Written submission

Post or email to the compliance committee. It is open to customers and suppliers as well as employees.

OPEN TO ALL
24 HOURS
Acknowledged

Receipt confirmed and a case reference issued to you, whichever route you used.

5 DAYS
Assessed

Initial assessment and assignment of an investigator with no reporting line to the people involved.

30 DAYS
Concluded

Investigation closed or an interim update given to you in writing.

CLOSE
Acted on

Outcome, corrective action and any policy change recorded in the register and reported quarterly to the board.

TRAINING

Signed is not the same as understood

Code of ethics training in week one, before any customer or supplier contact.
Annual refresh with scenario testing drawn from real cases, not generic e-learning.
Additional certified training for anyone handling trade controls, dangerous goods or personal data.
Managers are assessed on how their teams raise concerns, not on how few they raise.
CONSEQUENCES
What a breach means

Breaches are handled consistently regardless of grade, revenue impact or how long someone has been here. Deliberate breaches of the anti-corruption, trade control or safety commitments are treated as gross misconduct, and we report to the relevant authority where the law requires it. Supplier breaches trigger suspension pending investigation and, where substantiated, termination of the agreement.

NEXT STEP

Work somewhere that writes it down

Published bands, and one code that applies to every role.