Letter to Suppliers about Compliance with Applicable Laws and Regulations
February 1, 2023
RE: Compliance with applicable laws and regulations, including the California Transparency in Supply Chains Act of 2010, Foreign Corrupt Practices Act, Victims of Trafficking and Violence Protection Act of 2000, Foreign Corrupt Practices Act of 1977, UK Bribery Act 2010, and the UK Modern Slavery Act 2015
Dear Supplier:
In accordance with Sun Chemical’s Code of Business Conduct (“Code”), we work with suppliers who contribute to sustainable development and are economically, environmentally, and socially responsible.
We want to take this opportunity to reinforce our support for and compliance with the applicable laws and regulations. Similarly, we also want to reinforce with our supply base that these laws and regulations are a priority for you and your extended supply chains.
Sun Chemical Corporation and all its affiliates (Sun Chemical) expect that all of its suppliers (including but not limited to direct raw material suppliers, indirect suppliers, and service providers) comply with applicable laws and regulations, including those intended to eradicate slavery and human trafficking as well as those intended to eliminate bribery and corruption. In particular, Sun Chemical requires that its suppliers comply with the California Transparency in Supply Chains of 2010 (CTSCA); the federal Victims of Trafficking and Violence Protection Act of 2000, and any amendments thereto, (VTVPA); and the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act 2010 (UKBA), UK Modern Slavery Act 2015 (UKMSA), and all applicable anti-slavery, human trafficking, anti-bribery laws of countries in which they do business.
Also, if any supplied goods include any amounts of tin, tantalum, gold, or tungsten, suppliers are required to certify that none of these minerals originated in the Democratic Republic of the Congo or any adjoining country and to comply with the conflict mineral provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
As a supplier of Sun Chemical, you certify that:
(i) no materials supplied to Sun Chemical are produced directly or indirectly by means of slavery or human trafficking; (ii) supplier complies with all applicable laws regarding anti-slavery and human trafficking in the countries, in which the supplier does business, including the CTSCA, VTVPA, and UKMSA; and (iii) supplier requires at least the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
(ii) it complies with all applicable anti-bribery laws of the country or countries in which supplier does business including the FCPA and UKBA, and that supplier requires the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
(iii) none of the minerals tin, tantalum, gold, or tungsten, which may be used in or constitute a part of any goods sold to Sun Chemical, originated in the Democratic Republic of the Congo or an adjoining country and the Supplier complies with the conflict mineral provisions of the Dodd-Frank Wall Street reform and Consumer Protection Act of 2010, and supplier requires the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
Further, as supplier of Sun Chemical you also promise to comply with Sun Chemical’s Code, including the policies on exchanging/giving/receiving gifts as stated in the Code in Chapters 6 and 7 (attached hereto and available under the following link:
http://www.sunchemical.com/legal/code-of-ethics/).
As Supplier of Sun Chemical, you further promise to require all of its suppliers of materials used in goods sold to Sun Chemical to periodically update certifications of compliance.
In the event any of supplier certification or covenant above ceases to be completely accurate or true, please notice that you are required to promptly notify Sun Chemical in writing.
Should you have any questions, please do not hesitate to contact your Sun Chemical contact or me.
Best regards,
Jeffrey Shaw
Chief Supply Chain Officer
February 1, 2023
RE: Compliance with applicable laws and regulations, including the California Transparency in Supply Chains Act of 2010, Foreign Corrupt Practices Act, Victims of Trafficking and Violence Protection Act of 2000, Foreign Corrupt Practices Act of 1977, UK Bribery Act 2010, and the UK Modern Slavery Act 2015
Dear Supplier:
In accordance with Sun Chemical’s Code of Business Conduct (“Code”), we work with suppliers who contribute to sustainable development and are economically, environmentally, and socially responsible.
We want to take this opportunity to reinforce our support for and compliance with the applicable laws and regulations. Similarly, we also want to reinforce with our supply base that these laws and regulations are a priority for you and your extended supply chains.
Sun Chemical Corporation and all its affiliates (Sun Chemical) expect that all of its suppliers (including but not limited to direct raw material suppliers, indirect suppliers, and service providers) comply with applicable laws and regulations, including those intended to eradicate slavery and human trafficking as well as those intended to eliminate bribery and corruption. In particular, Sun Chemical requires that its suppliers comply with the California Transparency in Supply Chains of 2010 (CTSCA); the federal Victims of Trafficking and Violence Protection Act of 2000, and any amendments thereto, (VTVPA); and the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act 2010 (UKBA), UK Modern Slavery Act 2015 (UKMSA), and all applicable anti-slavery, human trafficking, anti-bribery laws of countries in which they do business.
Also, if any supplied goods include any amounts of tin, tantalum, gold, or tungsten, suppliers are required to certify that none of these minerals originated in the Democratic Republic of the Congo or any adjoining country and to comply with the conflict mineral provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
As a supplier of Sun Chemical, you certify that:
(i) no materials supplied to Sun Chemical are produced directly or indirectly by means of slavery or human trafficking; (ii) supplier complies with all applicable laws regarding anti-slavery and human trafficking in the countries, in which the supplier does business, including the CTSCA, VTVPA, and UKMSA; and (iii) supplier requires at least the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
(ii) it complies with all applicable anti-bribery laws of the country or countries in which supplier does business including the FCPA and UKBA, and that supplier requires the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
(iii) none of the minerals tin, tantalum, gold, or tungsten, which may be used in or constitute a part of any goods sold to Sun Chemical, originated in the Democratic Republic of the Congo or an adjoining country and the Supplier complies with the conflict mineral provisions of the Dodd-Frank Wall Street reform and Consumer Protection Act of 2010, and supplier requires the same degree of compliance certified in writing from all of its suppliers of materials used in goods sold to Sun Chemical.
Further, as supplier of Sun Chemical you also promise to comply with Sun Chemical’s Code, including the policies on exchanging/giving/receiving gifts as stated in the Code in Chapters 6 and 7 (attached hereto and available under the following link:
http://www.sunchemical.com/legal/code-of-ethics/).
As Supplier of Sun Chemical, you further promise to require all of its suppliers of materials used in goods sold to Sun Chemical to periodically update certifications of compliance.
In the event any of supplier certification or covenant above ceases to be completely accurate or true, please notice that you are required to promptly notify Sun Chemical in writing.
Should you have any questions, please do not hesitate to contact your Sun Chemical contact or me.
Best regards,
Jeffrey Shaw
Chief Supply Chain Officer