Air Products is opposed to slavery, human trafficking and the use of forced labor of any kind. The Company has established policies and processes within its businesses and supply chains in support of this position.
The Company maintains and enforces a Human Rights policy which provides, among other things, that Air Products supports, encourages and values a diverse, multi-cultural workforce and is strictly opposed to the use of child labor or forced labor of any kind, including but not limited to slavery, indentured servitude, human trafficking and all other forms of forced labor. The Company’s Human Rights policy requires employees at all levels within the organization to abide by the policy.
Human rights are embedded in Air Products’ Employee Code of Conduct, which states that we follow all labor and employment laws in the countries in which we operate, including laws pertaining to child labor and employee rights, such as freedom of association, privacy, and equal opportunity employment. Employees are expected to follow the Code of Conduct as a condition of employment. Training is required of all employees, and training compliance is reviewed regularly with the Chief Compliance Officer. Employees who do not comply with the Code of Conduct may be subject to termination of employment and/or criminal prosecution in some cases. As allowed by local law, managers and supervisors may be subject to disciplinary action and/or personal liability for failure to address violations committed by employees.
Employees are expected to report suspected violations of the Human Rights policy, Employee Code of Conduct, and other policies. Reporting allegations of misconduct is completed through a variety of reporting systems that are continually monitored. Allegations are reviewed, referred to appropriate investigative resources, and entered into a case management system where the progress of the investigation is monitored by an independent observer. A strong non-retaliation policy is upheld for good faith reporting. During 2018, no allegations related to slavery and human trafficking were submitted via any of the reporting systems.
Suppliers are also required to abide by the aforementioned Code of Conduct in their business dealings with the Company and to support the principles outlined in Air Products’ Expectations of Suppliers. Air Products has instituted a supplier prequalification process that includes review of business and risk factors. Critical suppliers are included in the Company’s Supplier Relationship Management (SRM) program that requires annual planning and review sessions. SRM also includes supplier risk assessments that are used to understand and address existing and potential risks, including labor and Code of Conduct issues. The Company has defined procedures for noncompliance and remediation, and joint company-supplier corrective action plans.
Air Products routinely requires its suppliers, vendors and contractors to contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business, including but not limited to all laws, rules and regulations relating to slavery and human trafficking. Air Products managers, in consultation with the Law Department, are trained to ensure that such clauses are routinely included in contracts. Air Products may also require its suppliers, vendors and contractors to demonstrate a commitment to Human Rights and an opposition to slavery and human trafficking by providing Air Products with a copy of its own Human Rights or Anti-Slavery/Human Trafficking policy. Air Products may further require its suppliers, vendors and contractors to complete certifications, satisfactory to Air Products, certifying that the materials incorporated into the products they supply to Air Products comply with all laws regarding slavery and human trafficking in the countries in which they do business.
Air Products’ Corporate Audit department occasionally conducts audits and verifications of existing contractual agreements within the Supply Chain organization to ensure compliance with contractual terms, including but not limited to contractual terms relating to legal compliance. Air Products generally does not hire third parties to conduct audits or verifications for such purposes, although it reserves the right to do so in appropriate circumstances. Audits are generally conducted upon 30 days advance notice.
Air Products is concerned that the trade of Conflict Minerals mined in the eastern provinces of the Democratic Republic of the Congo may be fueling human rights atrocities in the region. Air Products has evaluated the potential for Conflict Minerals to be part of its supply chain. The Company has reviewed its product lines and identified those that might contain the minerals. For each of the covered products a good faith Reasonable Country of Origin Inquiry (“RCOI”) has been conducted. Where required, the company conducts supply chain due diligence in accordance with OECD guidance, engaging suppliers who have been identified as providing the Company with materials that either contain or potentially contain Conflict Minerals. In addition, the Company has provided its suppliers with information about conflict free sourcing, and implemented provisions for new and renewed supply contracts that require suppliers and their sub-contractors to provide supply chain transparency about the source of any Conflict Minerals.
Questions regarding Air Products’ commitment to eradicate slavery and human trafficking, both within its own organization as well as within the organizations with whom Air Products does business, may be addressed to Julie O'Brien, Sustainability Director.
Chairman, President and Chief Executive Officer
The above information has been provided as required by the UK Modern Slavery Act of 2015 and the California Transparency in Supply Chains Act of 2010.