Transparency in Supply Chain (TISC) Statement

Transparency in Supply Chain (TISC) Statement

1.  Introduction

As a responsible corporate citizen, Sun Chemical Group Cooperatief U.A. (and its subsidiary and/or affiliated companies) seeks to ensure that quality and safety standards are maintained throughout our supply chain by well-treated and fairly compensated workers in accordance with all applicable laws.

This TISC Statement constitutes Sun Chemical’s anti-slavery and human trafficking statement for the financial year ending 31st December 2023. It is in line with section 54(1) of the U.K. Modern Slavery Act 2015 and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act. It is also consistent with Sun Chemical’s disclosure regarding the California Transparency in Supply Chains Act of 2010.

2.  Sun Chemical Corporate Structure

Sun Chemical, a member of the DIC group, and its subsidiaries (together the “Group” or “We”) is a leading producer of printing inks, coatings and supplies, pigments, polymers, liquid compounds, solid compounds, and application materials. Sun Chemical Group operates in North America, Latin America, Europe, Asia and the Pacific region. Together with DIC, Sun Chemical has annual sales of more than $8.5 billion and over 22,000 employees supporting customers around the world.

This TISC Statement covers the steps taken by specific Group companies to ensure that slavery and human trafficking is not occurring in those businesses.

3.  Policies

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains.

The Group refrains from using gold tantalum, tungsten, and tin that are mined in conditions of armed conflict and abuse in the Democratic Republic of the Congo.

The Group does not use any products made in whole or in part from any good from the Xinijang Uyghur Autonomous Region in China, as prohibited by the Uyghur Forced Labor Prevention Act (“UFLPA”).

The DIC Group Code of Business Conduct prohibits forced or compulsory labour and child labour. The DIC Group Code of Business Conduct applies to all companies in the Group including those identified above.

The Group has revised its Human Rights Policy setting out procedures and guidelines for anti-slavery or human trafficking within our business.

The Group also has in place a policy to protect whistleblowers who highlight to us any risk of slavery or human trafficking within our businesses.

As part of the DIC Group Policies mentioned above, the Group provides appropriate training to all executives and employees in order to ensure the effectiveness of these policies. The prohibition of forced labour and child labour is a key aspect in this training.

4.  Due Diligence Processes

We ask our suppliers to verify in writing whether they have policies in place on elimination of child and illegal labour.

Further we have started to screen our vendors on compliance topics via an integrated and digital compliance tool. By doing this we are mitigating the risk that corruption or modern slavery takes place in our supply chain.

In 2020 we added a Transparency in Supply Chain clause in the UK Terms of Purchase to assure that our vendors are aware of this topic and agree to comply with the relevant regulations.

Sun Chemical uses the EcoVadis platform to rate the Corporate Social Responsibility of its supply base, thus managing and reducing risk in the supply chain. Information about Sun Chemical’s sustainable procurement initiative can be found in its Corporate Sustainability Report.

Sun Chemical has added a slavery and human trafficking section to the current UK Supplier Risk Assessment and to the Supplier Questionnaire for the selection of new Suppliers managed by Local Direct Purchasing.

5.  Further Steps

In line with the EU Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), the Group is executing risk assessments on all ESG topics to assure compliance with these directives.

We will consider more intense measures, such as auditing or third-party verification for any suppliers that we determine are of medium or high risk. If we suspect a supplier is involved in such activities, we will conduct an inquiry and, if necessary, take corrective action promptly.

For and on behalf of Sun Chemical Group Cooperatief U.A. and Sun Chemical Ltd


Name: Martijn Schoonenberg LL.M

Job Title: Assistant General Counsel & Company Secretary

Date: 30th June 2024

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Letter to Suppliers about Compliance with Applicable Laws and Regulations