Ethics and Compliance Policy
It is the policy of Styron to be lawful, high-principled and socially responsible in all of its business practices. We expect our employees to learn and comply with all corporate policies and laws applicable to their job responsibilities and outlined in the Styron Code of Business Conduct and supporting policies.
All Styron employees, officers and directors must share Styron’s commitment to ethical business conduct. The Styron Ethics and Compliance program and standards apply to all employees in all regions.
Styron’s activities related to Ethics and Compliance are overseen by the Associate General Counsel and Chief Compliance Officer, who also chairs Styron’s Ethics and Compliance Committee. This Committee, which reports to the Audit Committee of Styron’s Board of Directors and is responsible for the oversight and management of the Ethics and Compliance program, is comprised of nine senior Styron executives representing diverse functions and geographies.(1)
In that role, the Ethics and Compliance Committee reviews, and when necessary modifies or updates, the Code of Business Conduct and its supporting policies on an ongoing basis. The Committee also oversees the responses to any ethics or compliance reports or questions, conducts or monitors any investigatory activity, and assists in communicating the ethics and compliance program to Styron’s employees and the public.
Most Styron employees embrace the company’s high ethical standards. Occasionally, however, individuals may act in a way that reflects poorly on Styron and its people.
Styron encourages employees who know or suspect that a legal or ethical violation has occurred or is taking place to speak up and report the situation.
Styron has zero tolerance for any reprisal or retaliation against a person who reports a known or suspected violation of any such obligation in good faith. Styron will take disciplinary action, up to and including termination of employment, against any employee involved in threatened, attempted or actual retaliation.
Employee Training and Communication
Styron provides periodic updates on its compliance efforts using various internal communications tools, such as news stories and Intranet content. In addition, an employee presentation has been developed for leaders to use in their work groups to outline the Styron Ethics and Compliance program.
In 2012, Styron launched a web-based Ethics and Compliance training module for employees.
Styron’s Code of Business Conduct is the foundation for the company’s Ethics and Compliance program. The Code provides a framework to make the right choices. It directs us how to be lawful, highly principled and socially responsible in all of our business practices in every region where we operate. Translations will be made available as they are completed.
The Code summarizes many of the ethical principles and policies Styron has adopted to deal with issues such as environmental health and safety, competition laws, bribery, and equal employment opportunity.
Ethics and Compliance Hotline
Styron has contracted with a third-party, one of the global leaders in its field, to provide an ethics and compliance hotline, which allows anonymous reporting of ethics and compliance concerns or allegations where legally possible. Any individual inside or outside the company who has a concern about ethics and/or compliance at Styron is encouraged to report the issue to the company’s ethics and compliance hotline.
