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California Transparency in Supply Chains Act

This page serves as Saudi Basic Industries Corporation’s (SABIC’s) disclosure under the California Transparency in Supply Chains Act.

SABIC’s commitment to a strong compliance culture is fundamental to the Company’s continued growth as a world leader in chemicals. Here you will find our policies and procedures aimed at eradicating slavery and human trafficking from our supply chain of the goods offered for sale in the State of California.

1. Verification of product supply chains to evaluate and address risks of human trafficking and slavery

All suppliers who, according to our risk assessment criteria, are deemed high and medium risk, are required to complete a questionnaire which includes questions that evaluate and address risks of human trafficking and slavery. The pertinent questions are directly pulled out of our supplier questionnaire and pasted below.

  • Please provide details about your Corporate Social Responsibility (CSR) Management and tell us who buyers should contact if they have a question.
  • Have any directors of your organization been convicted of a criminal offence relating to the conduct of, or in the course of, their profession or business, within the last five years?
  • Has your company been convicted for a breach of any labor laws in the countries you operate within the last five years?
  • If your company has been convicted for a breach of any labor laws in the countries you operate within the last five years, what steps have you taken to ensure this does not happen again?
  • Has your company been convicted for the use of forced / bonded or prison labor and harsh disciplinary measures within the last five years?
  • If your company has been convicted for the use of forced / bonded or prison labor and harsh disciplinary measures within the last five years, what steps have you taken to ensure this does not happen again?
  • How does your organization prevent the use of child labor? If not relevant, please explain why. 
  • Has your company been convicted for a breach of any child labor laws in the countries you operate within the last five years?
  • If your company has been convicted for a breach of any child labor laws in the countries you operate within the last five years, what steps have you taken to ensure this does not happen again?
  • Does your organization retain evidence with regard to the age of employees?
  • What evidence does your organization retain with regard to the age of employees?
  • Please specify the other evidence that your organization retains with regard to the age of employees
  • Does your organization provide accommodation for any of its workforce?
  • Does all accommodation provided by your organization for its workers provide well‐maintained and adequate drinking water, toilets and showers for the number of occupants?
  • Does all accommodation provided by your organization for its workers provide well‐maintained and adequate heating and cooling?
  • Where legally required, are all workers paid a minimum wage for all hours worked?
  • Has your company been convicted for a breach of any social and ethical requirements in the countries you operate within the last five years?
  • If your company has been convicted for a breach of any social and ethical requirements in the countries you operate within the last five years, what steps have you taken to ensure this does not happen again?
  • Does your organization have a documented policy to ensure that neither slavery nor human trafficking takes place within your organization?
  • Please upload a copy of your organization’s anti‐slavery or human trafficking policy.
  • Does your organization have a documented policy to ensure that neither slavery nor human trafficking takes place within its supply chain?
  • Please provide details of what your organization does to prevent slavery or human trafficking in its supply chain.
  • Please provide any additional information related to Corporate Social Responsibility.

2. Audits of suppliers

High risk suppliers are subject to an on‐site audit. The audit checklist contains several elements related to workers’ ages, pay, living conditions, etc. Inquiries for an on‐site audit are posed in several stages.

Relevant inquiries for the initial stage, or desktop audit, include:

  • Does the minimum salary paid by the company provide the employee with a basic salary that allows for making a living according to local standards? (Auditor to record minimum wage applied in the facility)
  • Are all workers issued a contract of employment or other document confirming terms of employment?
  • Can the company demonstrate that it has a process for the assessment and management of employee fatigue e.g. limitations on working hours?
  • Can the company demonstrate that it does not use bonded / forced labor?
  • Does the company ensure that there is no money, deposit, or credits of its employees kept as a condition of employment in the company or does the company ensure that credits that could create dependencies of the worker are not granted?
  • Are all employees in the company free within the legal framework and upon the discussion with their employer to terminate their employment on their own decision?
  • Are all employees allowed to leave the company property after contracted hours/regular working time?
  • Are all workers provided with written and understandable information about their employment conditions with respect to wages (e.g. weekly or monthly payment periods) before they enter employment? Are workers informed about the particulars of their wages for the pay period?
  • Does the company have a policy relating to the minimum age of workers /employees? (Auditor to record age of youngest workers employed within the facility)
  • Does the company make sure that young workers below 18 years of age are exempt from overtime, night work and hazardous work?
  • What form of worker representation is there on site?

If the supplier being audited is an on‐site contractor, advanced stage inquiries also include:

  • Does the supplier verify the competencies/capabilities of all agency‐supplied labor prior to being supplied to them?
  • If workers are utilized via recruitment agencies or labor companies, are checks made to verify that all workers are entitled to work in the specified country?
  • Can the company demonstrate how they prevent bullying/harassment in the workplace?
  • Are details of the process or system communicated to all members of staff?

3. Requirement of direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the countries in which they are doing business

Each purchase order for products and services used in the manufacture of SABIC’s goods offered for sale in the State of California contains the following language:

(vi) no products transferred under the Purchase Agreement (1) have been or will be produced utilizing forced, indentured or convict labor or utilizing the labor of persons in violation of the laws governing minimum working age, minimum wage, hours of service, and overtime in the country of manufacture.

Additionally, SABIC has created a Supplier Code of Conduct, and requests each SABIC supplier globally to agree to adhere to its principles. Included in the principles are provisions regarding fair employment, such as prohibitions on forced labor and child labor and a requirement to adhere to applicable laws on wages, working conditions, hours, and more.

If a supplier does not agree to adhere to our Supplier Code of Conduct, either because it does not have a code or it adheres to its own, further review by SABIC’s Legal Department is required before the supplier can be approved. If the supplier uses its own code of conduct, SABIC requests a copy of that code and conducts a review to ensure the following areas are adequately addressed: 1) environment, health, safety and security; 2) anti‐bribery; 3) fair competition (antitrust); 4) international trade controls; and 5) fair employment practices. If the supplier does not have its own code and will not adhere to the Supplier Code of Conduct we provide, SABIC inquires about the reason and the Legal Department evaluates accordingly.

The SABIC Supplier Code of Conduct can be found on SABIC’s supplier portal at https://supplier.sabic.com/sor/refDoc/SABIC%20Supplier%20Code%20of%20Conduct.pdf.

4. Accountability standards and procedures for employees or contractors that fail to meet company standards regarding slavery and human trafficking

The SABIC Code of Ethics provides the foundation for our business culture and underscores our commitment to performance with integrity. The Code of Ethics provides guidelines for employee behavior and affirms our commitment to uphold our core values such as our commitment to our employees, standards for doing business, and our relationship with our communities. We embrace the SABIC Code of Ethics, every day and in every business dealing across the globe.

Our Code of Ethics Policy on Third Party Business Dealings contains the following provisions:

Our Responsibility FOLLOW APPLICABLE LAWS AND OUR POLICIES and require any supplier or third party who works with SABIC to comply with applicable laws and our policies. Consult Company legal counsel for the appropriate language to use in all contracts with suppliers and third parties.

Concerns to Look Out For UNSAFE CONDITIONS, DISREGARD OF ENVIRONMENTAL STANDARDS OR UNDERAGE EMPLOYMENT at supplier or other third party facilities.

Questions & Answers

Q: A new low‐cost supplier offers good quality and reliable delivery at very competitive prices. You are concerned about the working conditions it provides its workers. Do you award business to this supplier?

A: Our reputation requires us to do business only with suppliers that deal responsibly with their workers and local environments. In light of your concerns, you should consult with your manager and Company legal counsel to determine appropriate steps to determine the suitability of the supplier. The full SABIC Code of Ethics can be found at Code of Ethics.

5. Employee and management training on slavery and human trafficking

All SABIC employees receive training on the Code of Ethics. Employees can seek compliance guidance from their managers, Legal Affairs, Human Resources and over 65 Compliance Helpline Leaders worldwide. Trained personnel investigate all incidents in a timely manner. We investigate all credible reports of suspected misconduct. Confirmed violations are addressed with corrective actions, including employee discipline or dismissal.

In addition, within our Procurement function, training that includes employment practices such as minimum age, forced labor, wages, and overtime has been provided in the past and given to our auditors as well.


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