GENERAL / ETHICS & COMPLIANCE

Five documents. No local exceptions.

Chemtive moves restricted materials, hazardous goods and other people’s money across eighteen jurisdictions. These five policies govern how, for employees, agents and every supplier in the chain.

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5
GOVERNING POLICIES
18
COUNTRIES, ONE STANDARD
240
SUPPLIERS SCREENED
0
SUBSTANTIATED CASES FY2025
THE POLICY SET

Five documents, and what each one commits us to

Business conduct & ethics code
REV 4 · JAN 2026 · 24 PAGES

The single code every employee signs on joining and re-signs each January. It sets out the eight commitments, the four-question decision test, and what happens when someone breaches them.

KEY COMMITMENTS
Honest representation of specification, origin and availability.
Zero tolerance of bribery and facilitation payments.
Sanctions, dual-use and end-use screening on every transaction.
Safety authority for every employee to stop work.
Accurate records that survive an audit unchanged.
Anti-corruption policy
REV 3 · JAN 2026 · 18 PAGES

Applies to every employee, agent, broker and intermediary acting on our behalf, in all eighteen operating countries and regardless of local practice.

KEY COMMITMENTS
No bribes, kickbacks or facilitation payments in any form or amount.
Gifts and hospitality declared above €100 and never around a tender decision.
Agents and brokers due-diligenced before appointment and re-screened annually.
No political donations of any kind, anywhere.
Charitable donations approved centrally and published in the annual report.
Whistleblowing procedure
REV 2 · JUN 2025 · 12 PAGES

Four protected routes to raise a concern, with published timings. Retaliation against anyone reporting in good faith is itself a dismissible breach.

KEY COMMITMENTS
Line manager, compliance officer, external hotline or written submission to the committee.
Anonymous reporting supported in local languages, 24 hours a day.
Acknowledged within 24 hours; assessed within 5 days; concluded or updated within 30.
Investigators have no reporting line to anyone involved.
Open to customers, suppliers and contractors, not only employees.
Code of conduct for suppliers
REV 2 · SEP 2025 · 16 PAGES

Signed by every producer, agent, toll manufacturer, broker and logistics partner as a condition of the commercial agreement.

KEY COMMITMENTS
ISO 9001 as a minimum, with quality and HSE certificates on file and current.
No forced, bonded or child labour, verified by audit rather than declaration.
Freedom of association and a living wage in the country of operation.
Environmental permits, emissions data and waste handling disclosed on request.
Right of audit, and suspension pending investigation of any substantiated concern.
Modern slavery statement
ANNUAL · FY2025 · 14 PAGES

Published annually under the UK Modern Slavery Act and equivalent EU reporting duties, covering our own operations and our supply chain.

KEY COMMITMENTS
Risk assessment across 240 suppliers, with 38 classified higher risk by geography and sector.
22 on-site audits completed in FY2025, four corrective action plans opened.
Recruitment agency fees paid by Chemtive, never by the worker.
Training for procurement, logistics and HR teams on indicators and escalation.
Zero substantiated cases in FY2025; two concerns investigated and closed.
GOVERNANCE

Who owns this, and who checks it

Compliance reports to the board directly, not through the commercial line it has to police.

BOARD
Audit & compliance committee
Meets quarterly, reviews the case register in full, and approves every policy revision.
GROUP
Chief compliance officer
Named, contactable directly by any employee, supplier or customer, with no reporting line to sales.
REGION
Regional compliance leads
One per region, responsible for local law, trade controls and screening in their markets.
EXTERNAL
Independent assurance
Annual third-party audit of the programme, with findings published in the annual report.
DOCUMENTS

Request the set

Business conduct & ethics codeREV 4 · JAN 2026 · 24 PAGESREQUEST ↗Anti-corruption policyREV 3 · JAN 2026 · 18 PAGESREQUEST ↗Whistleblowing procedureREV 2 · JUN 2025 · 12 PAGESREQUEST ↗Code of conduct for suppliersREV 2 · SEP 2025 · 16 PAGESREQUEST ↗Modern slavery statementANNUAL · FY2025 · 14 PAGESREQUEST ↗Complete policy packZIP · 5 DOCUMENTS · 12.4 MBREQUEST ALL ↗
NEXT STEP

Something does not look right?

Four protected routes, one anonymous, all acknowledged within 24 hours.